Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 1 Growing Risk Addressing the Invasive Potential of Bioenergy Feedstocks

Home , Arundo, Biodiesel production, Camelina, Camelina sativa, Eichhornia crassipes, Miscanthus

Growing Risk Addressing the Invasive Potential of Bioenergy Feedstocks

Aviva Glaser and Patty Glick 2012

Prepared by Aviva Glaser, Legislative Representative, Agriculture Policy Patty Glick, Senior Climate Change Specialist

Acknowledgements This report was made possible due to the generous support of the Doris Duke Charitable Foundation.

The authors wish to thank many people for their time and contributions to this report. We would like to thank the following National Wildlife Federation staff for providing valuable edits and feedback: Julie Sibbing, Bruce Stein, Doug Inkley, and Lara Bryant. Additionally, we would like to thank several experts for their time, input, and helpful review comments: Dr. Joseph DiTomaso, University of California, Davis; Dr. Doria Gordon, The Nature Conservancy; Bryan Endres, J.D., University of Illinois; Dr. Lauren Quinn, University of Illinois; Doug Johnson, California Invasive Plant Council; and Read Porter, J.D., Environmental Law Institute.

Cover image: The highly-invasive giant reed (Arundo donax), a candidate species for bioenergy production, has taken over vast areas along the Rio Grande, as seen in this aerial view near Eagle Pass, Texas. Credit: John Goolsby, USDA.

Suggested citation: Glaser, A. and P. Glick. 2012. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks. Washington, DC: National Wildlife Federation.

i Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Table of Contents

Little bluestem, a native grass. Credit: NRCS.

1. Executive Summary 1

2. Overview 3 The Promise of Bioenergy 3 Risks from Bioenergy 4 A Focus on Invasiveness 4

3. Invasive Bioenergy Feedstocks: A Major Concern 7 Invasive Plans Can Wreak Havoc on Ecosystems and Society 7 Weediness: A Characteristic of a “Good” Biomass Plant 8 Harvesting Existing Invasive Plants: Win-Win or Pandora’s Box? 9 Adding Climate Change to the Mix 10 Selective Breeding and Genetic Modification 11 The Myth of Total Sterility 12

4. Case Studies of Feedstocks of Concern 14 Giant Reed (Arundo donax) 14 Miscanthus (Miscanthus species) 16 Genetically Modified Eucalyptus (Eucalyptus grandis x Eucalyptus urophylla) 18 Reed Canarygrass (Phalaris arundinacea) 20 Algae 22 Napiergrass (Pennisetum purpureum) 24

5. Minimizing the Risks: The Importance of Embracing Precaution 26 Current Regulation of Invasive Species 26 Screening Tools 32

6. Conclusions and Recommendations 34 Concluding Thoughts 41

7. Endnotes 42

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks ii 1

Executive Summary

ithout question, America needs to transition to a cleaner, more sustainable W energy future. As we move forward with our energy choices, we must be mindful of how short- term economic decisions can come with unintended consequences and high long-term costs to society and the environment. Bioenergy is one homegrown source of renewable energy that could help meet some of our energy needs. However, in order to create a truly clean energy future, bioenergy must be produced in a way that has long-term economic viability, helps address climate change, and protects and enhances native habitats and ecosystems.

The explosion in federal and state mandates and incentives for renewable energy in recent years has led to a greatly increased demand for cheap and plentiful biomass from a variety of plants and microorganisms. This increased demand for bioenergy has led to considerable interest in a number of non-native and potentially invasive species that are currently being cultivated or considered for use as bioenergy crops. In fact, some of the very characteristics that make a plant particularly useful as a source of biomass energy (e.g., rapid growth, competitiveness, tolerance of a range of climate conditions) are the same characteristics that Parabel grows non-genetically modified, native aquatic make a plant a potentially highly invasive species. plants in Florida to use as a renewable energy feedstock. Credit: Julie Sibbing. Widespread cultivation of exotic and genetically modified species for bioenergy is becoming increasingly likely. In order to create a truly clean energy Should these species escape cultivated areas and enter nearby habitats, the results could be devastating for future, bioenergy must be produced in a native ecosystems as well as the economy. Very little is way that has long-term economic viability, known about the full potential scope of the problem, yet the industry is moving full speed ahead. Already, there helps address climate change, and are examples of intentional cultivation of biomass species that are known to be invasive or have the potential to protects and enhances native habitats become invasive. For instance: and ecosystems.

4 • Giant reed (Arundo donax) is being used as a bioenergy As a result, invasive species that we may have been able crop in Florida, despite the fact that it has been known to inhibit are causing widespread environmental and to invade important riparian ecosystems and displace economic harm. habitat for native species in states across the southern half of the country. We now have an opportunity to prevent irreparable harm by heeding sensible precautions. With foresight and careful • Reed canarygrass (Phalaris arundinacea), which is screening, we have important opportunities to minimize considered to be one of the most harmful invasive species and, where possible, prevent negative impacts of biomass in America’s wetlands, rivers, and lakes, is being proposed feedstocks on the nation’s communities and ecosystems. for cultivation as a bioenergy feedstock in several areas, We recommend some key actions to help ensure that the including the Eastern Upper Peninsula of Michigan. next generation of bioenergy does not fuel the next invasive species problem. • Cylindro (Cylindrospermopsis raciborskii), a type of algae that is associated with toxic algal blooms in the Great 1. Future bioenergy development should encourage Lakes region, is just one of many non-native or modified ecological restoration and improve wildlife habitat through strains of algae under consideration for bioenergy, even the use of ecologically beneficial biomass feedstocks such though the fast growth rate of algae and the inherent as waste materials and sustainably collected native plants difficulty in containing them is a major concern. and forest residues.

• Napiergrass (Pennisetum purpureum), also called 2. Federal and state governments should conduct elephant grass, has been listed as an invasive plant coordinated efforts to restrict or prohibit the use of in Florida and described as one of the most problematic known invasive species as dedicated bioenergy weeds in the world, and yet BP is currently developing feedstocks through rigorous Weed Risk Assessment a cultivated variety of it as an energy crop in the Gulf (WRA) screening protocols. Coast Region. 3. State and federal governments should implement In addition, the use of already highly-destructive invasive rigorous monitoring, early detection, and rapid response plants for bioenergy, including Chinese tallow (Triadica protocols, paid for by feedstock producers through sebifera), kudzu (Pueraria montana var. lobata), Eurasian insurance bonding or other financial mechanisms. watermilfoil (Myriophyllum spicatum), and common reed (Phragmites australis), is being proposed as a way to 4. Feedstock producers should adopt best management capitalize on the potential benefits of the plants while plans for monitoring and mitigation to reduce the risk providing an opportunity for their control. While this of invasion. may allow for a win-win for ecosystem restoration and renewable energy production, it also raises the concern 5. The federal government should assign liability to that the active re-establishment of the invasive species, feedstock producers for damages from and remediation of rather than their control, might be incentivized. invasions by feedstock varieties that they develop.

The severity of this threat is by no means trivial. Every 6. Governments and businesses should better account year, invasive species cost the United States billions of for the economic risks associated with invasiveness of dollars and affect countless acres of native ecosystems. feedstocks when assessing relevant costs and benefits of Researchers estimate that nearly half of the species listed potential bioenergy projects. as threatened or endangered under the U.S. Endangered Species Act are at risk, at least in part, due to the impacts Bioenergy can be an important part of a sustainable energy of invasive species. Despite this, few safeguards exist future, but only if it is produced in a way that safeguards in law and in practice to prevent the spread of invasive native ecosystems and minimizes the risk of invasion. species. To date, current laws and regulations dealing with invasive species have been reactive and piecemeal.

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 2 2

Overview

s the world focuses greater attention on finding alternatives to fossil fuels in order to A meet our growing energy demands, reduce carbon emissions, and enhance global security, interest in expanding the use of bioenergy has grown considerably. Bioenergy – also called biomass energy – refers to the energy resources derived from plants and animals or their metabolic products. Sources of biomass can include trees, annual and perennial crop plants, algae, and other plants, as well as some organic waste materials and byproducts from other manufacturing processes (See Box 1, page 5). When these feedstocks are used to produce energy in the form of liquid fuels, such as ethanol and biodiesel, they are referred to as biofuels. Biomass can also be used to produce energy in the form of heat and electricity generation. Indeed, the use of wood for cooking and heating has long been a part of human history.

The Promise of Bioenergy

One of the attractions of bioenergy is that unlike fossil fuels, which have a finite global supply, bioenergy can be grown and used repeatedly – and thus can be considered a form of renewable energy. Renewable energy (including wind, solar, geothermal, and biomass Native perennial grasses have great potential as energy crops. energy) is becoming an increasingly important part Credit: ©iStockphoto.com/Prairie Art Project. of America’s energy portfolio. According to the U.S. Energy Information Administration, renewable energy’s One of the attractions of bioenergy is market share reached 8 percent of total U.S. energy consumption in 2009.1 In addition, many states have that unlike fossil fuels, which have a finite enacted minimum renewable energy requirements for both transportation and electricity generation. Currently, global supply, bioenergy can be grown biomass is the largest contributor to renewable energy in and used repeatedly – and thus can be the United States and around the world, and accounts for about 11 percent of total primary energy consumed.2 considered a form of renewable energy. Research suggests that increased production of energy from biomass resources may have the potential to considerably offset the use of fossil fuels.3,4

3 Credit: DOE Office of Biological and Environmental Research.

In addition, the production and use of bioenergy is being Furthermore, as mentioned above, research has found widely touted as a way to help mitigate climate change.5,6 that not all bioenergy is actually carbon neutral, and, Ideally, biomass fuel production and use would be at depending on a number of factors, some forms of least “carbon neutral.” In other words, feedstocks absorb bioenergy may in fact lead to increased emissions of 13,14 carbon dioxide (CO2) as they grow, and the carbon is CO2 For example, it can take more than 50 released back into the atmosphere when the plants years for trees to regrow and recapture the total are harvested and used for energy, with no net gain in carbon released when mature trees are used for atmospheric carbon. In principle, feedstocks have the bioenergy. While bioenergy holds great promise for potential to even be “carbon negative” if more carbon is meeting some of renewable energy needs, the impact taken up than is released, as root stocks develop and store of unsustainable bioenergy development could be carbon. Ultimately, net increases in atmospheric CO2 would devastating to natural resources. slow if truly carbon neutral bioenergy resources displaced the use of fossil fuels, which increase atmospheric carbon A Focus on Invasiveness by transferring carbon from subterranean reserves into the atmosphere when combusted. However, it is critical While all of the concerns associated with the expansion to acknowledge that the greenhouse gas implications of of bioenergy require careful consideration, this report bioenergy are complex, and that climate-related benefits focuses on only one of these concerns – the potential 7,8,9 cannot automatically be assumed. invasiveness of bioenergy feedstocks – an issue that has only recently begun garnering significant Risks from Bioenergy attention.25 Numerous studies have shown that some of the plants considered most promising in terms of As with all energy resources, it is important to recognize bioenergy capacity may actually be extremely invasive that development and use of bioenergy has both benefits and potentially quite harmful to native species in areas and costs, and there is potential for considerable societal, where they have been introduced.26,37,28,29 History has economic, and environmental tradeoffs. There are a repeatedly shown that introductions of invasive species, number of environmental concerns associated with the even when well-intentioned, can lead to widespread use of bioenergy, including the loss or degradation of unintended environmental and economic consequences. native ecosystems, declining soil and water quality, and As Raghu et al. (2011) aptly state, “[t]he road to species the invasive potential of the feedstocks themselves.10,11 introductions is often paved with good intentions, but is One of the key issues related to bioenergy is land use. littered with their consequent legacy.”30 As demand for bioenergy grows, so will the areas of land needed for growing biomass feedstocks. The Invasive species (including plants, animals, and other implications of this for other current and potential uses of organisms) are one of the primary threats to North land to meet competing needs, such as food production, America’s native species and ecosystems. An invasive are significant.12 Of particular concern for biodiversity species is defined by the federal government as “an alien conservation is the potential for natural areas such species whose introduction does or is likely to cause as forests or grasslands to be converted to cultivated economic or environmental harm or harm to human bioenergy cropping systems or monocultures. health.”31 While only a small percentage of the estimated

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 4 Box 1. The Importance of Fostering a New Generation of Bioenergy Feedstocks: Moving Beyond Corn-based Ethanol

n the early stages of bioenergy development, the primary feedstocks in the United States I have included corn, sugar cane, and other annual food and feed crops for ethanol, wood for heat and electricity, and to a lesser extent, palm, sunflower, and rapeseed for biodiesel and other oils. Corn, in particular, has been the predominant bioenergy crop. In 2010, the United States produced 13.2 billion gallons of corn-based ethanol, making it the world’s top producer of the fuel at 57.5 percent of global production.15

Production and use of bioenergy in America is expected to continue to grow considerably over the next decade. Under the 2007 Energy Independence and Security Act, the nation has set a Renewable Fuel Standard (RFS) to significantly increase the proportion of bio-based fuels for transportation, from current production levels of over 13 billion gallons a year to 36 billion gallons by 2022. This would account for about 7 percent of the expected annual gasoline and diesel Corn has been the predominant bioenergy crop in the U.S. consumption above a business-as-usual scenario.16 Credit: Fishhawk on flickr.

Under the law, the total use of ethanol from corn is bird species.22 In addition, there are concerns that capped at no higher than 15 billion gallons. Over the expansion of corn production for bioenergy could the last few years, some troubling ecological and further exacerbate water quality problems in some economic issues have arisen regarding the use areas due to expansion in the use of agricultural of corn as a bioenergy feedstock. For example, a chemicals and nutrients such as nitrogen and number of studies have found that the cultivation phosphorous.23,24 and production of corn-based ethanol typically consumes more energy than it ultimately generates, While the nation’s demand for corn-based ethanol given the relatively large amount of fertilizers, will likely continue to grow in the near-term until pesticides, and other energy-intensive inputs and it reaches its cap, there has been strong interest activities required.17,18,19,20,21 Researchers have also and effort to identify new “advanced” or “second found that expansion of corn production has led to generation” bioenergy feedstocks that can optimize reduced populations of already declining grassland energy outputs with fewer economic or environmental

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5 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks inputs. Particular emphasis is being placed on cellulosic (defined as renewable fuel derived from plants cellulosic bioenergy, which is produced from fibrous that achieves a 60 percent reduction in greenhouse plant material from such things as perennial grasses gas emissions compared to gasoline) and advanced [such as reed canarygrass (Phalaris arundinacea), bioenergy (renewable fuel derived from biomass other switchgrass (Panicum virgatum), miscanthus than corn starch that achieves a 50 percent greenhouse (Miscanthus spp.), and giant reed (Arundo donax)] gas reduction requirement). As this report highlights, and fast-growing trees [such as poplar (Populus spp.), however, these next generation feedstocks are not willows (Salix spp.) and eucalyptus (Eucalyptus spp.)]. necessarily more benign than their predecessors. While Research is also being conducted on the potential for they may be potentially more productive and efficient so-called “third-generation” bioenergy resources from than first generation feedstocks, next generation algae and other “micro crops”. Ultimately, more than feedstocks also pose a greater risk of becoming invasive. half of the total volume of the RFS must come from

50,000 non-native (exotic, alien) species in the United damage by invasive species in the United States is at States are invasive, those that are can cause tremendous least $120 billion annually.40 The annual cost associated ecological problems and often lead to considerable with plants alone is estimated at $34.5 billion.41 economic impacts.32,33,34 This report: Once introduced into a new environment, invasive plants can out-compete native species for limited • Reviews the current state of knowledge on the resources such as space to grow, light, nutrients and invasive potential of plants being considered water.35 Invasive animals (including insects) can harm for use for bioenergy, native forage or prey species, as well as compete with • Profiles six of these potentially invasive native animals for forage and prey. Invasive diseases of feedstocks, plants and animals can spread rapidly in native species • Discusses methodologies for screening feedstocks that have little or no resistance. Invasive species can and mitigating potentially invasive properties, have a significant impact on ecosystems as well as • Provides an overview of the legal and policy human societies by disrupting food webs, decreasing framework within the United States that could biodiversity, altering important ecosystem functions such minimize or mitigate this risk, and as fire ecology, damaging agriculture and infrastructure, • Offers a series of policy recommendations. and harming human health.36 In addition, researchers estimate that nearly half of the species that are listed as threatened or endangered under the U.S. Endangered Species Act are at risk due, at least in part, to the impacts of invasive species (including plants, animals, and microorganisms).37,38

Efforts to control invasive species, combined with economic losses due to the degradation or destruction of critical ecosystem functions, can cost billions of dollars a year in the United States.39 In fact, analysis suggests that the economic damage associated with control of and

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 6 3 Invasive Bioenergy Feedstocks: A Major Concern

Invasive Plants Can Wreak Havoc on Ecosystems and Society

Exactly how many invasive plants species currently exist in the United States is unknown. However, we do know that some of the most harmful plants were brought in intentionally for horticultural, agricultural, and forestry purposes.42,43,44,45 For example, three species originally introduced for landscaping and erosion control purposes, including purple loosestrife (Lythrum salicaria), kudzu (Pueraria montana var. lobata), and saltcedar (Tamarix spp.), have turned out to be among the most highly invasive and damaging species in the country.46,47

Other problematic species were purposefully introduced for use as livestock forage [e.g., johnsongrass (Sorghum halepense)] or were released by accident via contaminated crop seed or other commodity imports [e.g., cheatgrass (Bromus tectorum) and cogongrass (Imperata cylindrica)].48 Even species that are native to some parts of the country have proven to be harmful invasives when introduced elsewhere. One notable example is smooth cordgrass (Spartina alterniflora). Highly-invasive kudzu covering everything in its path. Smooth cordgrass is the predominant emergent salt Credit: James H. Miller, USDA Forest Service, Bugwood.org. marsh species throughout much of the Atlantic and Gulf coasts, where it plays an important role in the All too often, the extent of the coastal ecosystem. Given its ability to control erosion, the species was introduced to parts of the Pacific problems created by an invasive Coast, where it has out-competed native marsh plants and significantly altered critical mudflats and other species is not fully recognized until coastal habitats.49 a landscape or ecosystem has been Very little attention has been given to the potential dramatically modified. for non-native bioenergy feedstocks to host harmful diseases. The very real risk of disease in introduced plants is demonstrated by the fact that kudzu is a host species for Asian soybean rust (Phakopsora pachyrhizi), which was first reported in the continental United States

7 in 2004. It is a serious disease that can cause significant resistant to pest and insect outbreaks, and able to damage to soybean crops.50 Similarly, members of the thrive in marginal environmental conditions – including myrtle family (Myrtaceae), including eucalyptus trees, poor soil and drought. Unfortunately, many invasive which are potential bioenergy feedstocks, have been species, by their very nature, exhibit these qualities as found to host Puccinia psidii, a rust fungus that has well (See Table 1).55 Accordingly, plants considered to severely damaged an endangered native myrtle species be good bioenergy candidates are often more likely in Hawaii.51 to become invasive; researchers found that in Hawaii, for instance, approximately 70 percent of the plants All too often, the extent of the problems created by an proposed for use as biofuel feedstocks had a high risk invasive species is not fully recognized until a landscape of becoming invasive.56 or ecosystem has been dramatically modified.52 Studies have found that there is often a time lag of several decades or more between the time that a non-native species has been introduced and when we realize it In fact, evidence indicates that in has become a harmful invasive. By the time an invasive most cases, species invasions are species has become established, they are exceedingly difficult to control, let alone eradicate.53 In fact, evidence essentially irreversible. indicates that in most cases, species invasions are essentially irreversible.54 Indeed, several exotic grass species that are currently Weediness: A Characteristic of a under consideration for use as bioenergy feedstocks, including giant reed, reed canarygrass (Phalaris “Good” Biomass Plant arundinacea), and miscanthus (Miscanthus spp.), are already considered invasive in some areas of the Ultimately, the goal of bioenergy production is to create United States.57 In California alone, more than $70 the greatest amount of energy possible while minimizing million dollars has been spent over the past 15 years to inputs such as fertilizer, agricultural chemicals, water, control giant reed, which has caused extensive damage and planting and tillage operations. Thus, the optimal to ecosystems and human infrastructure in many of feedstock to maximize bioenergy production would the state’s coastal and inland watersheds.58 Reed be one that is fast-growing, highly productive, highly canarygrass has displaced native species on thousands competitive, self-propagating or able to regrow rapidly,

Table 1. Characteristics of Ideal Biomass Crops vs. Invasive Weeds61 Characteristic of an Characteristic Known to Ideal Biomass Crop Contribute to Invasiveness Rapid growth rate x x Resistent to pests and diseases x x High water use efficiency x x

C4 photosynthesis* x x Perennial x High yields x x Sterility x Ability to grow in a wide range of climates and habitats x x Rapid regrowth or self-propagation x x

62 * Plants with the C4 photosynthetic pathway use water more efficiently under arid conditions than plants with 3C photosynthesis.

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 8 of acres of wetlands in southern Wisconsin.59 In addition, Chinese tallow, for example, has become widely some native species under consideration as bioenergy established across much of the South, and is known for feedstocks have the potential to become invasive if its prolific production of oil seeds. One study suggests introduced outside their native range.60 that conversion to commercial use of 500,000 acres of non-crop upland areas in southwestern Louisiana that Harvesting Existing Invasive currently host dense stands of tallow trees has potential to produce 80-140 million barrels of biodiesel within a Plants: Win-Win or Pandora’s Box? decade.67 In addition, there is interest in using some of the world’s most damaging aquatic invasive plants, Several studies suggest that some highly-problematic including water hyacinth (Eichhornia crassipes), hydrilla invasive plant species could be used for biomass, (Hydrilla verticillata), Eurasian watermilfoil (Myriophyllum creating an economic incentive for controlling the spicatum) and common reed (Phragmites australis), species. For example, Sage et al. (2009) estimate that for bioenergy due to the desire for resource managers the amount of standing biomass of kudzu in naturally to control overgrowth, as well as the fact that these infested areas of Maryland, Alabama, and Georgia is plants have significantly higher productivity rates than high enough to significantly supplement existing biofuel many terrestrial bioenergy feedstock candidates.68,69 feedstocks, assuming economical harvesting and Researchers are also looking into the potential for using 63 processing techniques could be developed. Given its several invasive algae species, including Gracilaria invasive growth habit, the authors suggest that there salicornia, which is prevalent in coastal waters would be little in the way of input costs for fertilizers, throughout the Hawaiian Islands, and Didymosphenia pesticides, planting, and stand management. Benefits geminata, which is rapidly expanding in streams across may also accrue by offsetting some of the estimated the United States.70,71.72,73 $500 million per year cost to the nation from lost crop and forest productivity, expenditures for control, and The primary issue regarding use of already-problematic property damage. invasive plants for bioenergy production is whether such uses will contribute to reducing the species’ invasion and restoring the invaded ecosystem, or whether potential economic gains from their use will encourage efforts to maintain their presence on harvested landscapes, or even lead to their cultivation and expansion into new areas. In fact, some researchers suggest that, instead of reduction, continued cultivation of the invasive species is acceptable, particularly in cases where the plants have become “naturalized” and where restoration to prior ecosystem composition and/or function is no longer feasible or possible – such as with Chinese tallow.74 However, Davis et al. (2010) describe such proposals as a “Faustian bargain, with inadvertent creation of a lobby dependent upon maintenance of infested areas for fuel and employment.”75 It would likely be difficult for the Water hyacinth, seen in this picture invading a stream, has been bioenergy industry to refrain from supporting expansion suggested as a potential bioenergy feedstock. Credit: Kim Starr. of these feedstocks into new areas. Another issue of concern is that the active use of invasive feedstocks Two other species, Chinese tallow (Triadica sebifera or for bioenergy not only creates a sustained source of 64 65 Sapium sebiferum) and saltcedar, which are both origin for propagules, it also creates a transportation listed by The Nature Conservancy as among the nation’s infrastructure associated with harvest and use for “Dirty Dozen” least wanted intruders, have also been bioenergy, which will undoubtedly increase the pathways 66 suggested as potential feedstocks for bioenergy. for spread into other areas.

9 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Soil erosion due to flooding. Climate change is likely to contribute to an increase in extreme events such as flooding, which can help spread invasive species long distances. Credit: NRCS.

Furthermore, efforts focused specifically on reduction the invasiveness of some bioenergy feedstocks. For and control of currently-problematic plants must contend example, studies have found that some invasive species with the fact that the use of the particular feedstock is may have a competitive advantage in systems disturbed not sustainable – once the resource is depleted, other by extreme events such as floods, droughts, hurricanes, feedstocks will be necessary to continue to support and wildfires.76 Scientists project that climate change will bioenergy production. A potential avenue to get around contribute to an increase in the frequency and intensity of this dilemma would be through the creation of mobile such events in the coming decades.77 Although impacts bioenergy production facilities, which could move will vary across different regions, understanding where locations once a particular invasive species has been and how these changes might occur can help determine harvested and processed. Mobile production units whether certain feedstocks under consideration for may also help to reduce the risk of invasion created bioenergy production might have a potential to become by transportation of invasive feedstocks. A number invasive as conditions warrant. For example, the of companies are currently investigating this type of spread of several invasive species, including giant reed, technology. Another idea is to purposefully establish a saltcedar, and Eurasian watermilfoil, has been directly non-invasive, vigorously growing bioenergy feedstock in tied to flooding events, whereby their propagules can an area on which an invasive has been removed, thus travel over long distances downstream – well beyond the preventing the invasive from becoming re-established capacity of land owners to control them.78,79 and ideally stopping its spread. This idea would be particularly appropriate for areas in which the invasion Furthermore, climate-related variables such as minimum has destroyed much of the native vegetation and the winter temperatures often serve as a natural barrier to wildlife habitat value has been depleted. the expansion of invasive plants and animals into areas that are climatically unsuitable for them. Indeed, climate Adding Climate Change to the Mix change is already contributing to an increase in average temperatures across the United States. Reflecting this Climate change is another issue that must be considered change, the U.S. Department of Agriculture (USDA) when assessing the potential invasiveness of bioenergy recently issued the first revision since 1990 of its map 80 feedstocks. While bioenergy is often touted for its of plant hardiness zones, showing a shift markedly potential to help mitigate climate change by reducing northward, consistent with climate change. In some areas, these changes may enhance the ability for net CO2 emissions, it is important to recognize that changes in the earth’s climate system are already potentially invasive plants to thrive where they may not underway and will continue into the future, even under have in the past. For example, recent research suggests the best case scenario for mitigation. Several factors that climate change is likely to contribute to a 2- to 10- associated with climate change are likely to exacerbate fold increase in highly suitable habitat for saltcedar in the

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 10 Northwest.81 Identifying areas with a suitable “climate of sterility is both to limit the chance of the GM plants niche” is one of the primary factors that managers will or their genes spreading outside of the area in which need to assess when locating bioenergy crops.82 It will they are being cultivated, and to ensure that farmers will be important to consider not only the existing climate continue to purchase seeds for the modified crops. conditions, but also how climate change is likely to affect an area’s future climate and thus its long-term suitability for specific biomass plants. ...GM and conventionally altered Another wild card is how competitive relationships plants may pose a contamination among plants will change with increases in atmospheric risk to the native ecosystems where CO2. Several of North America’s most noxious weeds, including Canada thistle (Cirsium arvense), spotted they reside, should the modified knapweed (Centaurea stoebe ssp. micranthos), versions spread. cheatgrass (Bromus tectorum), leafy spurge (Euphorbia esula), and kudzu are more likely to benefit from changes in atmospheric carbon dioxide concentrations than are native plants, thereby giving them another competitive There is considerable concern that GM and 83,84 advantage. As a general rule, plants with the C3 conventionally altered plants may pose a contamination photosynthetic pathway (a trait associated with most risk to the native ecosystems where they reside, trees and shrubs, and some grasses and sedges) are should the modified versions spread. Research on the more likely to have enhanced growth from elevated potential impacts of modified species that become

CO2 than plants using the C4 pathway (including many established outside of target areas is still in its infancy, feedstock candidates), assuming adequate water and and considerable uncertainty remains about the risks that

nutrients for growth. However, the C4 photosynthetic these species may pose relative to their wild relatives. pathway more efficiently uses water under warmer, drier Just as non-native species are not all necessarily

conditions than C3 plants. In areas where climate change invasive, modified plants do not all necessarily pose is projected to contribute to an increase in temperatures a risk to native ecosystems. The risk depends on the

and more extreme droughts, conditions for the C4 specific characteristics of the plant, where it is being candidate feedstocks may become more favorable. cultivated, and whether wild relatives of the plant are in the region, among other considerations. One study of Selective Breeding and the use of GM poplars as a biofuel feedstock suggests that the scope of the ecological issues expected from Genetic Modification their use is likely to be no greater than for “conventional plantation culture.”90 Other studies indicate that the Another issue of concern is the use of genetic risks are likely much greater in cases where non-native modification (GM) and selective breeding to enhance species are modified to improve their adaptability in areas or alter various characteristics, such as tolerance to where they might otherwise not be able to survive.91,92 cold, flooding, or salinity, for both non-native and native That is because modified plants may be able to breed feedstocks, modifications that some studies suggest with wild relatives, resulting in potentially-invasive hybrids. 85,86,87 could significantly increase the risk of invasiveness. In fact, research has found that hybridization between In the agricultural industry, selective breeding and GM varieties or disparate source populations may promote have been used for a number of purposes, including: evolutionary changes that enhance the invasiveness of increasing yield; enhancing nitrogen-use efficiency; exotic species over time.93,94 Hybrids are particularly and increasing resistance to conditions such as likely to occur in cases where there have been multiple droughts, cold temperatures, pests, and diseases – all introductions of a species or variety into a new area characteristics that can give plants a competitive edge and where invasiveness has occurred after a lag period 88,89 over non-altered, native plants. Additionally, GM is during which hybridization could occur. increasingly being used to alter the fertility of plants in an effort to ensure that the plants are sterile. The purpose

11 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Genetic modification has been used for many years for food crops, and thus it may be useful to look to these plants to better understand potential risks that GM may pose to ecosystems. According to a Government Accountability Office report, as of 2008 there were half a dozen documented cases in which GM crops were released into food, animal feed, or the environment unintentionally, but the total number of unauthorized releases into the environment was unknown.95 In a more recent incident that was not included in the report, a study found that herbicide resistant GM canola (Brassica napus) has been found growing along roadsides across North Dakota. Almost half of the roadside plants sampled for the study were GM canola, indicating that not only had the plants escaped from the areas in which they were cultivated, but that they had become quite common. Additionally, the researchers found that the escaped plants could hybridize with each other, creating entirely novel combinations of transgenic traits.96 Other studies have documented the transmission of the herbicide-tolerance gene from GM canola to wild relatives of the crop, such as wild turnips (Brassica rapa ssp. sylvestris).97

The Myth of Total Sterility

One way to reduce the risk of invasiveness is by promoting plant species that are unable to breed naturally. This can be achieved through several different means, one of which is to alter the fertility of the plants through genetic modification. In the case of GM eucalyptus, for example, scientists spliced in a gene Genetically modified canola plants have been found to escape known as the “Barnase gene” to limit the ability of the from the fields where they are cultivated. trees to reproduce; eucalyptus trees with the Barnase Credit: Karl Naundorf/Bigstock.com. gene produce flowers without viable pollen.98 Other times, companies rely on using hybrids between two ...by scaling up, we are also scaling up species. Hybrids between two plant species in the same family are often sterile – but not always. In fact, the chances of the “sterile” plant being there have been a number of cases where species that were thought to be sexually sterile have nonetheless able to create enough viable seeds that produced viable seed and become significant invaders.99 they may enter into nearby ecosystems. Sterility can, in fact, break down and a very small number of viable seeds could be formed.100,101 Even if this percentage is very small, the chance of reproduction may become significant when considering the fact that these species may be planted on a large scale. Giant miscanthus (Miscanthus x giganteus), for instance, is a sterile hybrid that is likely to be planted on hundreds of

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 12 thousands of acres in the next few years102 – by scaling It is important to recognize that even if a plant is unable up, we are also scaling up the chances of the “sterile” to create viable seeds, it is not necessarily incapable plant being able to create enough viable seeds that they of reproduction. Many plants are very capable of may enter into nearby ecosystems. As Low et al. (2011) reproduction through the growth of new plants through explain, “The large scale of proposed biofuels plantings vegetative means, such as underground rhizomes. will ensure high propagule pressure, so that even plants For example, giant reed plants do not produce viable with low invasion potential will have many opportunities seeds, but they propagate vegetatively (a form of asexual to escape.”103 reproduction in which a new plant can grow from a part of the parent plant) from even small stem fragments – a Indeed, there have been a number of examples of trait that enhances invasiveness.107,108 Giant miscanthus, so-called sterile plants becoming invasive. Townsend’s another sexually sterile plant, can spread through cordgrass (Spartina x townsendii) was a sterile hybrid underground rhizomes, although the rate of spread is developed in England that after a number of decades considered to be quite low.109 began producing fertile plants.104 Similarly, the Bradford pear (Pyrus calleryana), which was thought to be sterile, Feed stocks of concern ended up reproducing by seed and becoming invasive through cross-pollination with other cultivars; individual At least a dozen species of concern currently are being cultivars are not invasive themselves, but different used or considered for use as bioenergy feedstocks in cultivars within a region can combine and produce the United States. The following are just a few examples 105 invasive plants. In 1994, the Bradford pear was of some of these species. While not exhaustive, this list considered to have a very low invasion potential, but highlights some of the potential benefits as well as the after 10 years of ornamental plantings, it was found to risks – both ecological and economic – that we must have invaded natural areas in at least 26 states. The consider as we continue to build our bioenergy economy. species is now considered an invasive plant in at least six states, although it is not yet listed as a noxious weed in any U.S. state.106

Although the Bradford pear was thought to be sterile, the trees have become invasive in a number of states. Credit: Kenneth Keith Stilger/Bigstock.com.

13 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Giant Reed (Arundo donax) 4 Case Studies

iant reed (Arundo donax), also known as giant cane, is a large, fast-growing grass species native G to India. This perennial grass can grow between 9 and 30 feet tall.110 Originally introduced into the United States in the 1800s for erosion control and windbreaks, giant reed has become a nuisance weed in many states. However, its fast growth and high yield have led to its consideration as a biomass feedstock, and a number of projects across the country are underway and others have been proposed, despite the plant’s invasiveness.

Biomass Potential

Because it is fast growing and hardy, giant reed is considered to be a high quality source of biomass, with the potential to Aerial view of Arundo donax invading riparian areas near Big generate more than 20 tons of biomass per acre within two Bend National Park, Texas. Credit: John Goolsby, USDA. years of initial planting. In some warmer areas, such as the Gulf Coast, the plant may produce as much as 35 tons per acre.111 In addition to its high yield, giant reed can remove vegetative nodal fragment of giant reed floating downstream 120 toxins from the soil, and so may have the added benefit of soil can become established and form a large weedy stand. or remediation in degraded or polluted lands.112 Giant reed has been ranked as a likely invasive species on at least three published weed risk assessments (WRAs).121,122,123 Invasive Status and Risk of Spread Researchers applying one such WRA to giant reed in Florida concluded that the plant should be rejected for use as a biofuel

Giant reed is considered to be an invasive plant in much of crop, saying that “The combination of widespread distribution its introduced range around the world; in fact, it has been of giant reed propagules and inherent weedy characters listed as one of the world’s 100 worst weeds.113 In the United greatly increases the likelihood of escape and subsequent 124 States, giant reed is listed as a noxious weed in Texas,114 environmental damage.” Furthermore, it is unknown how California,115 Colorado,116 and Nevada.117 It has been noted as propagules may be spread in hurricane-prone regions of the either invasive or a serious risk in New Mexico, Alabama, and country, where much of the production is proposed. South Carolina.118 Giant reed in North America is not known to produce viable seeds, so technically it is considered to Potential Impacts be sterile. However, the plant can spread through vegetative reproduction, either through underground rhizomes or, more Because giant reed plants need lots of water, they commonly often, through culm (stem) fragments, which can grow roots invade riverbanks, riparian areas, and floodplains, competing and form new clones.119 Plant fragments can easily travel long for scarce water supplies. In California as well as Texas, giant distances downstream during storms, or become established reed has formed virtual monocultures along streams and rivers, 125 along roadways after the grass has been harvested and choking out native vegetation. Close to 30,000 hectares of is being transferred for processing. In fact, even a small riparian land in Texas are now estimated to be dominated by

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 14 giant reed.126 In California, a number of at-risk species, such North Carolina: ChemTex International, LLC is currently as the Least Bell’s Vireo (Vireo bellii pusillus), Southwestern pursuing plans to cultivate giant reed and giant miscanthus for Willow Flycatcher (Empidonax traillii extimus), and Yellow- use as a biomass feedstock in North Carolina. The company billed Cuckoo (Coccyzus americanus), could be significantly applied for a loan guarantee under the Biorefinery Assistance impacted by the displacement of native riparian vegetation Program for construction and operation of a biofuels refinery by giant reed.127 Giant reed also provides less shade to in Sampson County, North Carolina. According to the streams than native woody vegetation, which can lead to environmental assessment for the project, approximately 15- increased water temperatures and invasion of other aquatic 20,000 acres would be used for growing giant reed and/or plants, in turn affecting the habitat quality for aquatic wildlife giant miscanthus, with a production capacity of approximately species.128 Additionally, leaf litter in streams from giant reed 20 million gallons a year.137 Additionally, the U.S. Environmental that has invaded streambanks can lead to lower growth rates Protection Agency (EPA) recently issued a direct final ruling of aquatic invertebrates.129 in response to a petition from Chemtex allowing giant reed to qualify as a cellulosic biofuels under the Renewable Fuel Current or Planned Biomass Standard.138 After environmental groups, including the Uses and Risks National Wildlife Federation, submitted public comments raising concerns that the agency did not evaluate the invasive Florida: Florida Statute 581.083 limits cultivation of nonnative potential of the feedstock, EPA issued a notice withdrawing plants, including GM plants, for purposes of fuel production the final rule. EPA is currently in the process of addressing the 139 or other non-agricultural purposes in plantings greater in concerns through the full rule-making process. size than two contiguous acres.130 However, the state has granted several notable exceptions via special permits. In April Methods of Control 2010, the state of Florida approved one such permit to White Technology, LLC, to allow the planting of 80 acres of giant Once it has invaded an area, controlling giant reed is difficult reed for biomass energy.131 In January 2011, another permit to and costly. Manual removal techniques alone are often White Technology was approved for an additional 87 acres.132 not effective, as the plant has deep rhizomes from which Another company, Biomass Gas and Electric has also been it propagates. Chemical control using pesticides is usually interested in planting the species in Florida – particularly along necessary, which can create pollution problems, particularly the Gulf Coast – and has been funding a research project on since so much of the habitat in which the plant has invaded “genetic improvement” on giant reed.133,134 Giant reed has is near streams and rivers. Other techniques for control already invaded native plant communities in several parts include burning and biological control, though neither is very of Florida. While it is not currently classified as an invasive effective. Officials in a number of states are spending millions species in the state (it is considered “naturalized”), as of 2006, of dollars in an attempt to control the species. In California, for it was reported to be growing outside of areas where it was example, costs range between $5,000 and $17,000 per acre purposefully cultivated in 23 of the 67 counties in the state.135 to eradicate the weed. Other estimates put that cost as high as $25,000 per acre.140 While the net revenues for alternative Oregon: Around 100 acres of giant reed have been bioenergy feedstocks will vary considerably based on their planted in eastern Oregon for use as a biomass energy respective yields, input costs, and commodity prices, and time feedstock at the Boardman Power Plant. Based on the needed for the plants to reach maturity, the general range is success of this project, Portland General Electric will consider likely to be in the area of a few hundred dollars per acre per 141 planting as much as 70,000 to 80,000 acres of giant reed per year, by comparison. year.136 The town of Boardman is located along the Columbia River, which raises concerns given the plant’s ability to invade riparian areas.

15 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Miscanthus (Miscanthus species)

round 15 perennial species of grasses make up ability to reproduce vegetatively is a characteristic that is the genus Miscanthus. Because of their ability particularly associated with invasiveness.150 Because it can A to thrive on marginal, non-crop lands and their resprout from rhizomes, giant miscanthus could potentially fast growth rates, a number of these species have been spread during storm events, via transport to and from considered for their biomass potential, including Miscanthus production fields (e.g. falling off of trucks), through irrigation sinensis and Miscanthus x giganteus, also known as giant ditches and other waterways flowing near tilled field margins, miscanthus. Giant miscanthus, which has shown greater or even through animals that uproot plants in the fields, or a promise as a bioenergy crop in the United States, is a sterile host of other potential pathways. Studies have found that giant hybrid cultivar of two miscanthus species, Miscanthus sinensis miscanthus has a fairly low rate of spread,151 and has been and Miscanthus sacchariflorus. given a low-risk Weed Risk Assessment score by at least two sets of authors.152,153 Biomass Potential Of much greater concern than plantings of sterile giant Giant miscanthus has been widely grown in Europe for a miscanthus is research that is currently underway to field test a number of years as a bioenergy source. Research in the variety of giant miscanthus that produces viable seed.154 Giant United States has found that it is far more efficient than corn miscanthus that produces fertile seeds would significantly grown for ethanol and requires less land and inputs to grow.142 lower planting and establishment costs,155 but would also Additionally, giant miscanthus grown in Illinois was found to significantly increase the risk of invasion to an extent that is produce higher yields than switchgrass, a native grass that the wholly unknown – the wind could easily spread viable seed U.S. Department of Energy (DOE) has identified as a promising into natural habitats. Seed dispersal experiments with sterile feedstock for cellulosic biofuel.143 giant miscanthus indicate that the seeds can travel at least 400 meters in the wind.156 Given the invasive status of the parent Invasive Status and Risk of Spread species as well as the fast growth rate, large seed dispersal

Miscanthus sinensis, the parent species of the giant miscanthus, is listed as invasive species in Connecticut.144 Similarly, Miscanthus sacchariflorus, the other parent species of giant miscanthus, is listed on the Massachusetts prohibited plant list.145 The invasive potential of giant miscanthus is not yet fully understood; large scale production and field-size trials of the plant have only begun to be implemented in the United States.146 Giant miscanthus has been cultivated in Europe for over 30 years, and there have been no documented cases of the plant unintentionally spreading or escaping cultivation147,148 While giant miscanthus is a sterile hybrid cultivar, there is still concern that it could reproduce vegetatively. A number of features of giant miscanthus make it an ideal invasive weed—it has the ability to resprout from below the ground, it grows rapidly, and it has efficient photosynthetic pathways.149 The MIscanthus. Credit: Hazel Proudlove/Bigstock.com.

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 16 range, and low input requirements of the hybrid plant, the risk crops in the form of a cost-share and annual payments for five of invasion for seeded giant miscanthus could be quite high. years.160 As part of the BCAP program, USDA is funding a Additional study is particularly needed on the potential for project sponsored by Aloterra Energy and MFA Oil Biomass LLC seeded giant miscanthus to escape and become invasive. to establish and produce 200,000 acres of giant miscanthus in Missouri, Arkansas, Ohio, and Pennsylvania.161 After the final The way that giant miscanthus plantings are established has environmental assessment was published, USDA issued an major implications for how likely it is to become invasive. addendum for the project, stating that farmers must only use the Current projects in the United States mostly use giant Illinois clone of giant miscanthus, which is sterile. Additionally, miscanthus that is vegetatively propagated, due to the fact the addendum states that farmers must agree to a number of that the seeds of the plants are sterile. However, this method practices to reduce the potential for giant miscanthus to spread; leads to expensive planting costs, so other possibilities are for instance, farmers must monitor and report on the potential being considered, including the creation of seed production spread of giant miscanthus beyond the perimeters of the field, fields which could be planted with the two parent species and they must not plant giant miscanthus within 1300 feet of of giant miscanthus, M. sinensis and M. sacchariflorus. The any known M. sinensis or M. sacchariflorus plants to prevent fields would then generate the hybrid giant miscanthus seeds, cross-pollination.162 Additionally, the USDA recently released which could in turn be planted by farmers.157 The risk of viable a draft environmental assessment for another BCAP project, seed production by the giant miscanthus plants would still sponsored by the company REPREVE Renewables LLC, to pay be the same since they would still be sterile hybrid plants. farmers to plant an additional 58,000 acres in Georgia, South Although the fields will be harvested for seed before the seeds Carolina, and North Carolina.163 All of these acres would be disseminate, the creation of such seed production fields still planted with vegetatively propagated giant miscanthus. creates an invasion risk, particularly given the invasive nature of the parent species. In addition to the giant miscanthus projects, there are field trials underway across the country of a seeded variety Potential Impacts of giant miscanthus. Mendel Biotechnology has created the PowerCaneTM seeded miscanthus. The company is Miscanthus sinensis can displace native grasses and currently undergoing testing at sites across the country and dominate roadsides and pastures, likely because of its development trials in Georgia, Tennessee, Kentucky, Indiana, ability to tolerate harsh conditions such as poor soils, cold and California, as well as creating a series of best management temperatures, and shade.158 Studies have demonstrated that protocols for monitoring, reporting, and eradication.164 giant miscanthus may be more efficient and have higher yields Mendel is aiming for a commercial launch in 2014 or 2015. than native, locally adapted varieties of switchgrass.159 Should seeded giant miscanthus escape into natural Methods of Control ecosystems, it is certainly possible that it could outcompete native grass species. Giant miscanthus is only beginning to be planted in the United States and the economic costs of eradication are not yet Current or Planned Biomass known. Eradication studies indicate that 95 percent of the Uses and Risks aboveground biomass can be successfully eliminated through spring tillage, followed by an application of the In the spring of 2011, USDA made several announcements herbicide glyphosate; however, complete control of mature regarding funding for projects to grow biomass feedstocks stands of giant miscanthus are likely to require more than through the Biomass Crop Assistance Program (BCAP), which one growing season.165 was established as part of the 2008 Farm Bill. The program provides financial assistance to farmers in establishing energy

17 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Genetically Modified Eucalyptus (Eucalyptus grandis x Eucalyptus urophylla)

ative to Australia, eucalyptus trees are extremely eucalyptus species have a potential to produce over 15 fast growing, making them a potentially ideal dry tons of biomass per acre per year. Within 27 months, N source for woody biomass. However, many of the eucalyptus trees can grow as high as 55 feet - which is varieties of eucalyptus that are highly productive are very extremely fast, particularly when compared with the pine sensitive to freezing temperatures, particularly when they occur plantations that are currently growing in the Southeast.168 as cold snaps rather than as progressively colder temperatures in a winter season. To get around this problem, researchers Invasive Status and Risk of Spread have genetically modified eucalyptus to improve the trees’ tolerance of cold temperatures as well as droughts.166 These Genetically modified hybrid eucalyptus has not been grown genetically modified, hybrid eucalyptus trees (Eucalyptus in the United States until recently; the invasive potential of the grandis x Eucalyptus urophylla) also include a gene splice that species is unknown. One of the parents of the hybrid species, restricts the ability of the trees to reproduce. Eucalyptus grandis, is “predicted to be invasive” according to an assessment by the University of Florida.169 Additionally, Biomass Potential a number of other eucalyptus species are invasive in parts of the United States, including Eucalyptus globulus, which Certain eucalyptus species make ideal woody energy crops is listed in the California Invasive Plant Inventory.170 Because because they have high biomass productivity, a short rotation GM eucalyptus trees are spliced with a gene that restricts time, and relatively high levels of cellulosic carbohydrates their ability to reproduce, the companies that are producing (the primary resource for energy production).167 Some hybrid the trees believe that there is little to no risk that the trees will

Eucalyptus trees in Hawaii. Credit: Mike Brake/Bigstock.com.

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 18 become invasive and overtake natural forests. Yet field trials Current or Planned Biomass are just beginning for these trees, so there is no real proof that Uses and Risks the trees and their offspring will be 100 percent sterile.

In 2010, the USDA granted a permit to ArborGen, LLC to Upon granting the biotech company ArborGen a permit to grow GM eucalyptus trees in field trials on 330 acres in 28 begin field trials of GM eucalyptus trees in the southeastern sites. The sites are spread out in seven states throughout United States, the USDA issued a Finding of No Significant the south: Texas, Louisiana, Alabama, Mississippi, Florida, Impact on the environment, noting in particular the small Georgia, and South Carolina. This permit is in addition to a scale of the field trials and the specific conditions necessary previous permit given to Arborgen to grow GM eucalyptus on for tree growth.171 However, thousands of comments were 37 acres on 15 sites in the same seven states.177 The new submitted to the agency expressing concern about the permit was granted after the USDA’s Animal and Plant Health potential environmental impacts of genetically modified Inspection Service (APHIS) completed an environmental eucalyptus, including comments from the Georgia Department assessment for the controlled field trial and issued a Finding of of Natural Resources opposing the project in part because No Significant Impact.178 A number of environmental groups of concerns about invasiveness.172 One such concern is who were concerned that the environmental assessment was whether there is a chance for the transfer of the cold-tolerance not thorough enough took legal action against the USDA, but gene to non-sterile varieties of eucalyptus, which would the action ultimately failed.179,180 Additionally, it should be noted increase its potential to inhabit areas previously considered that multiple other non-GM species and hybrids of eucalyptus too cold. While the conditions associated with gene transfer are being developed for cultivation particularly in the southeast, are complex and uncertain and would likely depend on the some of which may be potentially invasive. mechanism of sterility, the potential for such hybridization is not 173 unprecedented between GM crops and their wild relatives. Methods of Control Potential Impacts Because genetically modified eucalyptus has not yet been widely adopted, the economic costs of control are unknown. Because so little is known about GM eucalyptus, the potential However, invasions by other species of eucalyptus have been impacts on biodiversity should the plants escape into the wild costly and difficult to control. For example, efforts to eradicate are uncertain. One concern is the potential for increased and Eucalyptus globulus through logging and other measures in widespread forest fires should the GM eucalyptus become Angel Island State Park in California took ten years; however, widespread, due to the fact that the oils in eucalyptus trees with logging and herbicide treatments, along with extensive may make the vegetation flammable and the bark of many can restoration of native communities, the efforts were successful.181 form fire brands that can spread fire far beyond the flaming front.174 Additional concerns have been raised that widespread invasion or plantings of GM eucalyptus in the southeast could have serious hydrological impacts, including altered groundwater levels and/or stream flow, which could potentially impact aquatic and terrestrial species.175 Furthermore, some eucalyptus species are known to have allelopathic qualities (i.e., they produce chemicals that impede the germination and growth of surrounding vegetation), which would limit the potential value of groves as wildlife habitat.176

19 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Reed Canarygrass (Phalaris arundinacea)

Reed canarygrass invading a riparian area in Alaska. Credit: Tom Heutte, USDA Forest Service, Bugwood.org.

native of Europe, Asia, and North Africa, reed Biomass Potential canarygrass was first introduced to the Pacific A Northwest in the early 1900s. Over the years, this Reed canarygrass is a particularly hardy species due to its tall perennial grass, which can reach up to heights of nine feet, ability to grow in wet soils and to tolerate droughts better has been used as a “breaking in” crop to help prepare former than most wetland species.184 Combined with high yields (in forested land for cropping, as forage for livestock, and more some states it has been found to produce higher yields than 182 recently as a water management tool. There are different switchgrass) reed canarygrass is a particularly good candidate ecotypes of reed canarygrass, and some speculate that there for biomass production.185 Additionally, reed canarygrass is may be an ecotype of the species that is in fact native to parts a cool-season grass, while many other grasses cultivated for of the northwest United States, although there has not been biomass like miscanthus and switchgrass are warm season 183 scientific consensus on the issue. grasses. Thus, it can be harvested in early summer when

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 20 warm-season grass biomass is not available, allowing for a potential in the Eastern Upper Peninsula (EUP) of Michigan, more constant biomass supply for a region.186 for instance, looked at both the use of currently existing acres of the invasive weed as well as the possibility of planting more Invasive Status and Risk of Spread and concluded that, “Reed canarygrass thus represents an economic potential for the EUP both in terms of reducing Reed canarygrass is currently present in 43 U.S. states.187 fuel costs and providing another source of income for area It is considered to be an invasive or noxious species in three farmers.”197 Reed canarygrass has also been tested for use as states: Connecticut, Massachusetts, and Washington.188 a biomass feedstock in Pennsylvania,198 Ohio,199 Wisconsin,200 Researchers at the University of Vermont have described reed and Iowa,201 among other places. canarygrass as “one of the most noxious invasive species in North American wetlands, rivers, and lakes.”189 Reed Methods of Control canarygrass can spread through seeds or plant fragments, or vegetatively through rhizomes. The latter pathway is typically Because it is such a hardy species, reed canarygrass is credited for its remarkable ability to spread. Reed canarygrass particularly expensive and difficult to control. It is resistant to spreads particularly well in disturbed areas, although it has also burning and flooding202 and has an abundant seedbank that been known to invade native wetlands. can last for years.203 Typical management regimes to eradicate stands of reed canarygrass include a combination of hand Potential Impacts pulling, mowing, burning, and chemical treatment over a few years, followed by monitoring for many more years. Reed canarygrass can be particularly problematic in wetlands and disturbed areas, outcompeting native species, forming dense mats, clogging shallow streams and ditches, and even impeding water flow.190,191 Once it has taken over wetland areas, the dense stands offer poor quality habitat for wildlife, such as waterfowl, that depend on wetlands for cover, habitat, and food.192 Reed canarygrass is estimated to have invaded thousands of acres of wetlands throughout the country.193 The weed is a particular problem for wet meadows in the Upper Midwest, where the grass forms dense monocultures and shades out native grasses and forbs.194 Native species that begin to grow in the late spring are particularly impacted by reed canarygrass.195

Current or Planned Biomass Uses and Risks

Reed canarygrass is currently being cultivated on thousands of acres for biofuel production in Europe,196 but it has yet to be adopted in the United States as a biomass feedstock in any capacity beyond research studies. However, there have been a number of studies devoted to assessing the potential of growing reed canarygrass in the United States for bioenergy production. A study looking at the weedy plant’s A field of reed canarygrass. Credit: Chris Evans

21 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Algae

ne of the fastest growing fields in biofuels research approximately two dozen is that of algae, including both microalgae (small non-native macroalgae O unicellular organisms, including diatoms and species found in Hawaiian cyanobacteria) and macroalgae (e.g. seaweeds such as waters, about half of which Laminaria, Sargassum, and Gracilaria species).204 This are reported as invasive.212 explosive growth has been driven in large part by the federal Statewide, the economic government, particularly the DOE, which has invested cost of controlling these millions of dollars in algae biofuels research and created a invasive algae is estimated National Algal Biofuels Technology Roadmap towards the at well over $20 million commercialization of algal biofuels. Algae are especially per year.213 promising sources of bioenergy because they do not require soil or arable land for growth – rather, they are cultivated in Given the vast number of freshwater or saltwater, either in open-air ponds or contained algae species in existence systems. There are thousands of species of algae, and both and the rapid pace of native and non-native algae species are being considered as algae research and Algae being processed for biofuel. 205 biomass feedstocks in the United States. Additionally, there genetic modification, there Credit: Sandia National Laboratories. has been considerable interest in genetically modifying algae is very little known about to optimize biofuel production.206 the invasion potential of the species that are currently being cultivated in labs and commercial facilities. However, several Biomass Potential traits specific to algae suggest the potential for invasiveness. For example, microalgae can easily aerosolize and spread, Algae are being evaluated and tested for use as a feedstock for leading to a high potential for such algae to escape from a production of starches for alcohol (i.e. cellulosic ethanol), lipids biomass production facility; indeed, and there have already for diesel fuel, as well as a source of hydrogen (H2) for fuel cells. been cases of algae escaping into the environment from Compared to terrestrial plants used for biomass, both microalgae research labs.214 Natural strains of algae from a California- and macroalgae more efficiently convert solar energy into usable based bioenergy company, for instance, “have been carried 207,208 energy. For example, per unit area, microalgae can produce out on skin, on hair, and all sort of other ways, like being blown up to 250 times more oil than soybeans. According to some on a breeze out the air conditioning system.”215 According to researchers, “…(p)roducing biodiesel from algae may be the a researcher at University of Kentucky, “complete containment only way to produce enough automotive fuel to replace current of algae is completely impossible.”216 This raises particular gasoline usage.”210 Additionally, algae are a particularly attractive concerns regarding the use of invasive, exotic, and genetically feedstock for biofuels because some species can be grown in modified strains of microalgae. While open ponds will likely saltwater or wastewater, and can be used to produce a variety pose considerably higher risk, even in a closed system, algae of fuel types.211 might be able to escape through ventilation systems or even on the clothes of workers. Macroalgae, which grow from Invasive Status and Risk of Spread spores, also may be transported unknowingly to new areas and remain dormant for some time before their growth is A number of species of algae are listed on various invasive spurred by favorable environmental conditions.217 species lists in the United States. For example, there are

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 22 Potential Impacts or non-native, and whether they are modifying the species. Below is just a small sampling of some of the companies and research facilities that are currently working on creating energy Little research has been conducted on potential for non- from algae: native or modified strains of algae cultivated for biomass energy to escape into natural ecosystems, and the potential • University of Nevada, in conjunction with Enegis, LLC impacts on biodiversity are not well understood. Proponents of and Bebout and Associates, created the first demonstration- genetically modified algae believe that the risks posed to native scale algae to biofuels project in Reno, Nevada.224 While they ecosystems are low and that the algae are unlikely to survive began their research using single-celled algae that grow in or thrive outside of highly controlled labs or facilities. However, saltwater, they now are experimenting with different types of the extraordinarily fast growth rate of algae as compared to algae that can be grown in wastewater, with the idea that the other genetically modified crops, combined with their ability to algae could both help to purify the wastewater and produce adapt to a variety of environments, concerns many others.218 renewable fuel.225 Should algae cultivated for biomass escape and become invasive, the impacts on biological diversity, and particularly on • Solazyme: One of the most well known and successful aquatic habitats, could be devastating. For example, across algae energy companies is Solazyme, which recently signed a the United States, the once-scarce Didyomosphenia geminata contract, along with some partners, to supply the U.S. Navy (also known as Didymo and “rock snot”) has been rapidly with 450,000 gallons of renewable fuels. The fuels will be made expanding in streams, where it grows into huge, slippery from used cooking oil as well as algal oil from Solazyme.226 mats that can expand the width of the river bed and crowd Using fermentation tanks, the company utilizes genetically out native plants. In addition, the non-native cyanobacterium modified microalgae in the absence of light to convert sugars Cylindrospermopsis raciborskii (or Cylindro), another bioenergy from plant feedstocks such as sugarcane-based sucrose or feedstock candidate, has been associated with toxic algal corn-based dextrose to create oil.227,228 blooms in the Great Lakes region.219 Introduced macroalgae also can have significant impacts on native ecosystems and • Aquatic Energy: Based in Louisiana, Aquatic Energy can change community dynamics through high abundance has an open-pond, freshwater algae farm in southwestern and monopolization of available space.220 The macroalga Louisiana that they use to create algal oil and meal, both of Gracilaria salincornia, for instance, has become prevalent which can be used by refineries to create fuels. According throughout the coastal waters of Hawaii, where it has rapidly to their website, the company uses non-genetically modified overgrown and smothered coral reefs.221,222 “proprietary algae strains, which are domestic and natural.”229 Current or Planned Biomass Methods of Control Uses and Risks

Should a species of algae become invasive and begin to affect At least a dozen oil companies and government research biodiversity or lead to economic losses, the cost of eradicating centers are currently working on genetically engineering algae the invader could potentially be considerable. For example, for renewable energy production,223 and many others are in southern California, the cost of eradicating one invasive working on creating renewable fuels from non-genetically marine macroalga, Caulerpa taxifolia, from one lagoon was modified algae. There are also an assortment of different approximately $3.34 million and took over five years.230 In types of projects being investigated, including both closed most cases, eradication of invasive algae probably is not even systems and open air ponds, each of which carries different technologically feasible. risks. Unfortunately, it is not always possible to find out which species a company is cultivating, whether the species is native

23 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Napiergrass (Pennisetum purpureum)

apiergrass, also called elephant grass, is a tall, clump-forming grass native to Africa. The plant has N been introduced in many tropical regions for use as a forage crop for livestock grazing, given its ability to quickly produce large amounts of biomass.231 It was introduced in the early 1900s to areas of Texas and Florida and promoted by the Bureau of Reclamation as a forage crop,232 but since then it has become a highly troublesome weed.

Biomass Potential

As with other fast-growing, rhizomatic grasses, napiergrass is considered a “premier biomass plant.”233 In the 1980s, it was used as a feedstock for methane generation and also was co-fired with coal to produce electricity. Today, it is seen as Napiergrass being cultivated in Florida. Credit: Julie Sibbing. a promising feedstock for cellulosic ethanol. In north-central Florida, it has yielded as much as 20 tons per acre per year in and it can grow very quickly. Because napiergrass is freeze- dry biomass, depending on available rainfall and fertilization. In intolerant, its potential spread (and use for bioenergy) is limited addition, it can be harvested twice a year, making it particularly to southern regions. useful as a dedicated energy feedstock. Research is currently underway to try to develop “non-invasive, genetically improved Potential Impacts genotypes” of napiergrass through elimination or reduction of gene dispersal of the species by pollen and seeds.234 Napiergrass is an invader of a number of different types of habitats and disturbed areas, including canal banks, fields, lake Invasive Status and Risk of Spread shores, swamps, croplands, and prairie habitats.241 Because of its dense growth, the grass prevents regeneration of native 242 Napiergrass has been identified as one of world’s most species by crowding out grasses, herbs, and tree seedlings. problematic weeds and is listed as a category 1 invasive Additionally, the dense growth of napiergrass can reduce water 243 species by the Florida Exotic Pest Plant Council.235,236 flows and block access to canals. Category 1 species are defined as “Invasive exotics that are altering native plant communities by displacing native species, Current or Planned Biomass changing community structures or ecological functions, or Uses and Risks hybridizing with natives.”237 Napiergrass has been documented in nearly 30 counties throughout the state, where it has taken Vercipia Biofuels, owned by BP Biofuels North America, has over areas of canal and ditch banks, blocking access and plans in the works to build what they believe will be the first impeding water flow.238 Napiergrass was ranked as having commercial-scale cellulosic biofuels production facility in the a high probability of becoming invasive on at least two country. Located in Highlands County, Florida, the facility published weed risk assessments (WRAs).239,240 Napiergrass will use a variety of different perennial feedstocks, including can reproduce both vegetatively and through seed dispersal, napiergrass.244 They are currently developing a seed farm to

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 24 Napiergrass. Credit: Dan Clark, USDI National Park Service, Bugwood.org. ensure sufficient quantities of the feedstocks.245 According to Methods of Control the EPA, continued development of napiergrass as a bioenergy crop is likely throughout much of Gulf Coast region, including The only ways to control napiergrass invasions are through Florida and southern portions of Texas, Louisiana, Georgia, mechanical or chemical means; however, because 246 Alabama, and Mississippi. Additionally, the EPA had recently napiergrass can spread easily via vegetative cuttings, tillage issued a direct final rule that would allow napiergrass (in is not recommended. In fact, according to researchers at addition to giant reed) to qualify as a cellulosic biofuels under the University of Florida’s Institute of Food and Agricultural 247 the Renewable Fuel Standard. However, after environmental Sciences (IFAS) Extension, “cultivation can actually cause groups submitted public comments raising concerns that larger infestations of napiergrass by breaking mature plants the agency did not evaluate the invasive potential of the into pieces and distributing them throughout the field.”249 feedstocks, EPA issued a notice withdrawing the final rule. EPA According to a researcher at the USDA, it is precisely because is currently in the process of addressing the concerns through the species is so difficult to control and eradicate that it has 248 the full rule-making process. become such a nuisance in tropical areas.250

25 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 5

Minimizing the Risks

The Importance of Embracing Precaution

As investments in bioenergy continue to grow, maximizing the benefits and minimizing the costs and unintended consequences associated with bioenergy development will be a key challenge. As this report has shown, the potential ecological and economic costs that would come if bioenergy feedstocks escape and become invasive are likely to be considerable. Yet, all too often the long-term costs associated with invasive species are not realized until it is essentially too late to avoid them. The potential for irreversible harm underscores the paramount importance of taking a precautionary approach.251

America must strive to better understand the risks of invasions from current and proposed bioenergy feedstocks and to focus our strategies – first and foremost – on prevention. Most critically, crops that are currently invasive or pose a significant risk of becoming invasive should not be cultivated as bioenergy feedstocks without comprehensive mitigation strategies in place that greatly reduce the risk of escape and invasion. It is important to note that non-native and genetically Switchgrass, a native grass, being harvested for bioenergy. modified feedstocks are not the only options available for Credit: Oak Ridge National Laboratory. bioenergy production. For example, using mixes of non- invasive plant species that are local to the region where America must strive to better they are being proposed for cultivation is a promising way to reduce the risk of invasion while still allowing for understand the risks of invasions profitable bioenergy production (see Box 2). from current and proposed bioenergy Current Regulation of feedstocks and to focus our strategies – Invasive Species first and foremost – on prevention.

In order to identify ways in which we can better reduce the risks from invasive bioenergy feedstock development, it is useful to understand the primary federal and state policies and programs governing invasive species

26 Box 2. Creating Energy from Native Plants

ot all bioenergy companies are focusing on non-native feedstocks. There are a number of N promising projects using native, locally adapted species as feedstocks. Other projects use sustainably harvested wood from forests or rely on waste and byproducts from manufacturing operations.

Show Me Energy

The Show Me Energy Cooperative, based in Missouri, offers a great example of how growing native plants for

bioenergy can be both profitable and environmentally- Native aquatic plants being grown for energy at Parabel. friendly. Show Me Energy is a biomass cooperative Credit: Julie Sibbing. that is owned and operated by over 600 farmers in 38 counties in Missouri and Kansas. These farmers collect from the aquatic plants is in the form of biocrude, a type residues from common agricultural crops, and also of oil made from biomass which can be converted into a plant native perennial crops on 50,000 acres of marginal number of different forms of energy.254 Parabel currently land using the best conservation practices available, has a commercial demonstration center in Fellsmere, including using polycultures and timing the harvest Florida, which has been in operation since 2009, and is for the late fall to avoid bird nesting and brood-rearing in the process of creating projects in Chile and Surinam season. The grasses and legumes currently used for using species that are local to the regions where the sites the project include: big bluestem (Andropogon gerardii), will be located.255 switchgrass, indiangrass (Sorghastrum nutans), Canada wild rye (Elymus canadensis), Virginia wild rye (Elymus Middlebury College Biomass Plant virginicus), purple prairie clover (Dalia purpurea) and Illinois bundleflower (Desmanthus illinoensis).252 In May 2011, In 2009, Middlebury College began operations of its $12 USDA announced that Show Me Energy would become million biomass gasification boiler as part of a campus the first dedicated energy feedstock project funded under plan to achieve carbon neutrality by 2016. The biomass the Biomass Crop Assistance Program. plant is fueled by wood chips – between 20 and 35 tons are delivered per day – all of which come from wood that Parabel is harvested within a 75 mile radius of the campus. Most of the wood chips are byproducts from local logging Previously called PetroAlgae, the Melbourne, Florida- operations or from mill waste. The biomass plant uses based company Parabel uses “micro-crops” of tiny, the wood to create steam, which then powers campus non-genetically modified aquatic plants to create both a heating, cooling, hot water, and cooking operations.256 renewable energy feedstock as well as a protein source The college is also investigating other potential sources of that can be used for animal feed and potentially as a biomass, and is currently using test plots to determine the human food.253 The energy that the company creates feasibility of growing willows near the campus.257

3027 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks and genetically-engineered plants. Importantly, the Box 3. Some Common Definitions development of policies to address invasive species has 258 necessitated clear definitions of relevant terms, such as Relevant to Invasive Species “alien,” “exotic,” “non-native,” “invasive,” and “noxious weed” as these terms often mean different things for different people (see Box 3). • Alien species. Generally defined as “species that spread beyond their native range, not necessarily harmful, Federal Regulation of Plant Species or species introduced to a new range that establish themselves and spread.”259 Similar terms include exotic While the problems associated with invasive species species, introduced species, and non-native species. have long been a national concern, the federal laws that currently address invasive species are generally a mixture • Non-native species. One of the most commonly of diverse provisions and multiple jurisdictions, which used terms to describe plant or animal species not often lack coordination and consistency.263 In its 1993 originally from the area in which it occurs. May be defined assessment of the nation’s invasive species programs, as “a species whose presence is due to intentional or the Office of Technology and Assessment concluded unintentional introduction as a result of human activity.”260 that “[t]he current Federal framework is a largely uncoordinated patchwork of laws, regulations, policies, • Invasive species. This term is often the subject of and programs,” and that invasive species issues “often confusion and debate. Under Executive Order receive governmental attention on a piecemeal basis 11322, it is defined as “an alien species whose after major infestations” have occurred.264 introduction does or whose introduction is likely to cause economic or environmental harm or harm to human Some of the most-developed laws regulating invasive health.” species are those associated with threats to agriculture under the authority of the USDA, although there are also • Noxious weed. Defined in federal law261 and in several laws that address threats to other economic most state codes, denoting special status of a plant as sectors, as well as fish and wildlife. While a complete restricted or prohibited. Commonly defined as “native or review of existing policies and programs is beyond non-native plants, or plant products, that injure or cause the scope of this report, there are several key statutes damage to interests of agriculture, irrigation, navigation, relevant for bioenergy feedstocks. For example: natural resources, public health, or the environment.”262 As a general rule, plants designated as noxious have Plant Protection Act of 2000. The Plant Protection regulatory restrictions, while other designations (e.g., Act of 2000 (PPA) consolidated USDA authority over invasive or non-native) do not. noxious weeds and plant pests into a single statute.265 Importantly, the PPA expands the definition of noxious weed, which previously had been defined under the 1974 Federal Noxious Weed Act, to include injury to the “environment.”266 Inclusion of a species on the federal Noxious Weed List prohibits subsequent movement of the plant within the United States. The statute, however, provides authority for prevention of noxious weeds, but not eradication or remediation of already established noxious weeds on private lands. Moreover, terrestrial species are often not included on the federal Noxious Weed List until harm is well documented and the species is established over large ranges across the United States.267 Although a 2004 amendment to the

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 28 PPA authorized USDA to provide financial and technical State Regulation of Invasive Plants assistance to state/local weed management agencies to 268 control or eradiate established weeds, Congress has State regulation of harmful plants dates back more than not appropriated funding for this program. a century, as many states recognized the threats that noxious weeds posed to agriculture. Today, states still U.S. Executive Order #13112. Although USDA bear the primary responsibility for the on-the-ground has the primary responsibility for noxious plant species prevention, control, and management of invasive species, control at the federal level, at least thirteen federal and each state government has developed unique and departments and agencies exercise some authority diverse webs of authorities to address different species over invasive species. To coordinate these efforts, in and, to a lesser extent, invasion pathways.276 1999 the President established via executive order the 269 National Invasive Species Council (NISC). Specifically, Typically, states use lists to identify species that should EO 13112 states: “Each Federal agencies whose be restricted and those that are considered safe. The actions may affect the status of invasive species shall, general rule has been the development of so-called to the extent practicable and permitted by law…not “black lists,” which regulate only species that have been authorize, fund, or carry out actions that it believes are designated as problematic by the legislature or agency. likely to cause or promote the introduction or spread ”White lists,” on the other hand, identify species that of invasive species in the United States or elsewhere the government deems “safe” – all other species are unless… the agency has determined … that the presumed to be harmful unless they have undergone benefits of such actions clearly outweigh the potential a process to determine that they are not.277 Currently, harm caused by invasive species; and that all feasible administrative agencies in forty-seven states (usually and prudent measures to minimize risk of harm will departments of agriculture, but occasionally departments be taken in conjunction with the actions.” Importantly, of natural resources) have authority to add species to this executive order could apply to federal subsidies directed to bioenergy crops that may have invasive Figure 1. Regulated plant species are characteristics.270 The new emphasis on prevention a function of both federal and state is important, as most prior efforts to address invasive noxious weed lists species largely focused on those that had already been introduced into the country. However, the particular challenge in addressing the potential invasiveness of a bioenergy feedstock under the efforts established under EO 13112 is how decision makers ultimately determine the respective “benefits” versus the “costs” or “harm” from its use.271

The Biomass Crop Assistance Program State noxious Federal noxious (BCAP). Congress established BCAP as part of weed list weed list the 2008 Farm Bill to provide assistance for farmers (varies by (7 C.F.R § 360.200) transitioning to biomass crops.272 BCAP was the jurisdiction) first federal subsidy program for the production of biomass.273 The program provides matching payments for the collection, harvest, storage and transportation of biomass (commonly referred to as CHST payments), as well as separate payments for the establishment of perennial biomass crops. CHST payments are available for the collection, harvest, storage, and transportation of existing invasive and noxious species,274 but USDA may not provide establishment payments in support of any plant that is noxious or invasive.275

29 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks their respective state noxious weed list. However, lists at of Florida’s Institute of Food and Agriculture Sciences the state level tend to be highly reactive—listing species (IFAS), may exempt non-native biomass plantings only after there is significant damage to agricultural from the permit requirement if it determines that plant is production or the environment. Additionally, state and not invasive. regional Invasive Plant Councils (IPC) or Exotic Pest Plant Councils—consisting of weed ecologists, land managers Conversely, because plant species have to be listed and other stakeholders—have the technical competence as noxious or invasive plants or be determined to be to identify potential invasive plant species, but often do invasive to be denied permits, the permitting process not have an advisory role, much less actual authority, to does not necessarily prevent the cultivation of potentially include these species on the state’s official noxious weed invasive plants such as giant reed (Arundo donax) lists. Demonstrating this disconnect between the IPCs or napiergrass (Pennisetum purpureum) that are not and the noxious weed lists, a recent study found that, on listed on Florida’s noxious weed list, unless the bond average, official state noxious weed lists only included represents a sufficient disincentive that cultivation plans 19.6 percent of the species considered invasive by the are abandoned. A proposed statute in Mississippi would respective state invasive plant council.278 Only five states enact a similar regulatory program, providing authority (MA, CT, OR, NH, and WA) had noxious weed lists that for the Department of Agriculture to deny permits for contained more than 50 percent of the invasive species invasive plants or plants with the potential to constitute identified by the respective IPC. a nuisance.280

The current multi-jurisdictional approach to noxious weed regulation leaves many terrestrial invaders largely unregulated at both the state and federal level, as these The current multi-jurisdictional plant species often are not included on either federal or approach to noxious weed state noxious weed lists (see Figure 1). State noxious weed lists, designed to supplement the federal list by regulation leaves many terrestrial tailoring invasiveness to state-specific ecosystems, invaders largely unregulated at generally fail to include known invasive plants. Moreover, both the state and federal level, as many states lack authority (or refuse to exercise their power) to enforce state weed control laws on private these plant species often are not property. Civil liability for the spread of weeds onto an included on either federal or state adjacent landowner’s property also varies widely across states, with some courts reluctant to require control over noxious weed lists. “natural” plants. Accordingly, there is minimal incentive for individual landowners to control noxious plant species absent an impact on agricultural productivity. Biotechnology Regulation

At least one state has been proactive in enacting a As is the case with invasive species, the regulation regulatory program designed to address the potential of genetically-modified (GM) products is handled by invasiveness of large-scale cultivation of bioenergy crops. multiple agencies under multiple statutes.281 The United In 2008, Florida implemented a permitting requirement States regulates the field testing and commercialization for cultivation of non-native plants (including genetically of GM plants under a 1986 agreement known as engineered plants) intended for biofuel production.279 the Coordinated Framework for the Regulation of Biomass plantings spanning more than two acres require Biotechnology (Coordinated Framework).282 This a permit from the Florida Department of Agriculture complex, multi-agency agreement sets up a trifurcated and Consumer Services. The permit also includes a regulatory system, with oversight by: 1) the USDA bonding requirement, the proceeds of which would to prevent introduction of agricultural pests under its fund eradication efforts of invasive bioenergy crops. Federal Plant Pest Act (PPA) authority;283 2) the EPA to The Department, in consultation with the University regulate pesticides incorporated into plant tissue through

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 30 its Federal Insecticide, Fungicide, and Rodenticide Act Two recent USDA decisions discussed below illustrate (FIFRA) regulatory powers;274 and 3) the U.S. Food and how GM bioenergy crops may avoid review under the Drug Administration (FDA), via the Federal Food, Drug, Coordinated Framework. In 2008, USDA determined that and Cosmetic Act (FFDCA),285 to ensure the general a GM petunia (Petunia) modified to produce a novel color safety of food and feed products produced with the use was not subject to regulation under the PPA because of GM technologies. neither the recipient, donor, vector, nor vector agent was a plant pest under existing regulations.287 As a plant not USDA’s authority to review GM plants under the PPA intended for food or feed, the GM petunia also avoided is premised on two statutory provisions: whether the FDA review under the FFDCA. Moreover, as the plant novel plant is a potential “plant pest” or a “noxious did not incorporate a pesticide or change the use of any weed.”286 Accordingly, USDA jurisdiction extends only to externally applied pesticide, the EPA lacked jurisdiction plants regulated as plant pests or noxious weeds—not to review the plant under its FIFRA authority. In sum, the every plant altered through genetic engineering. A GM petunia slipped through a loophole in the Coordinated plant would fall under USDA plant pest jurisdiction if Framework. In 2011, a variety of Kentucky bluegrass the donor, recipient, vector or vector agent used in the (Pao pratensis) genetically engineered to tolerate the genetic engineering is listed as a plant pest in the USDA herbicide glyphosate similarly evaded USDA review regulations or there is otherwise reason to believe it is under the PPA.288 Non-GM bluegrass was not listed as a plant pest. If the GM plant is believed to be a plant a plant pest and the organisms used as a source for the pest, introduction of the plant material may be allowed new genetic material to infer herbicide tolerance were without a permit, but only in accordance with specific similarly not regulated as plant pests. The USDA also criteria to ensure that it is contained. Only after field trials rejected a parallel petition to regulate the GM bluegrass demonstrate no significant risk of invasiveness can a as a noxious weed due to its herbicide resistance.289 company petition APHIS for non-regulated status. Moving forward, to the extent that novel GM bioenergy

Not all genetically modified plants are subject to regulation in the United States. Credit: Sebastian Duda/Bigstock.com.

31 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks feedstocks follow the pathway carved by the GM petunia and bluegrass petitions, and do not include plant incorporated pesticides subject to EPA review, or have residual uses as food or forage that may trigger FDA’s jurisdiction (e.g., USDA currently is conducting environmental assessments for eucalyptus trees genetically engineered for cold tolerance290), many novel dedicated bioenergy plants may forego the Coordinated Framework entirely.

Screening Tools

The considerable ecological and economic threat posed by invasive species has generated national and international protocols to screen non-native species being considered for human uses in order to evaluate potential risks. For example, Australia has developed a model weed risk assessment (WRA) system to screen all new plants before they enter the country by applying a “sieve” approach, which applies a set of questions to determine potential invasiveness and then approves some species, rejects others outright, and conditionally rejects the rest.291,292 Nearly a dozen independent studies found that the Australian WRA consistently was able to identify invaders.293 Additionally, the use of Genetically modified Kentucky bluegrass is currently not subject WRA has been found to provide net economic benefits to regulatory review by USDA. Credit: NRCS. by allowing authorities to screen out costly invasive species, even after accounting for potential revenues While WRA has proven to be an important and effective lost if a small percentage of plants have been rejected tool, several researchers suggest that some of the despite ultimately proving to be non-invasive.294 The more commonly-used risk assessment protocols may USDA has its own weed screening tool that is based on not address all of the issues that might determine the the Australian WRA,295 and a similar WRA approach has potential invasiveness of bioenergy crops, suggesting been developed specifically for aquatic plants.296 that more rigorous, “multi-tiered” approaches should be used – particularly in cases where initial analyses indicate Screening potential bioenergy feedstocks with programs conditional rejection.300 This may not only help identify like WRA is especially important because of the inherent species that are likely to be more problematic than initial invasive qualities of many potential feedstock plants.297 WRA may have indicated, but it also may help determine For example, a study that applied the Australian WRA where the risk might be lower than originally thought. approach in Florida and other areas of the United Davis et al. (2011), for example, found that additional States found that a majority of proposed bioenergy quantitative analysis of Camelina sativa, which would crops analyzed present an “unacceptable” invasion have been rejected under the Australian WRA protocol, risk in their respective target regions.298 In addition, a indicated that its invasive potential is only a concern if it is study that applied WRA to potential biofuel crops in cultivated in areas with disturbed soils.301 Hawaii suggests that, when compared to a sample of introduced non-biofuel species, biofuel crops were two- Other factors that warrant explicit consideration in to four-times more likely to be naturalized or invasive.299 WRA for bioenergy feedstocks include those related to cultivation and management practices.302,303 For

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 32 example, many biofuel feedstocks are harvested in late fall, after they have produced seed. This enhances the Screening potential bioenergy risk that the plants will be spread unintentionally when feedstocks is especially important the feedstocks are transported to storage or production because of the inherent facilities.304 Invasive potential also may be enhanced if biomass crops are planted over large geographical invasive qualities of many areas, where there is greater opportunity for escape. potential feedstock plants. Additionally, because there can be considerable difference in invasion potential between different varieties of the same species,305 it is critical that WRAs be used for each individual cultivar under consideration, not just each species. The sterile Illinois clone of giant miscanthus, for instance, is likely to have a much lower WRA score than PowerCaneTM giant miscanthus, which has viable seeds.

Finally, ecological risk assessments for bioenergy must address potential impacts of climate change, both near-term and long-term. So-called “climate niche” analysis is already commonly used by farmers and horticultural experts to determine regions of agronomic suitability (i.e., the ability to thrive in the particular climatic conditions and therefore require minimal additional inputs such as irrigation), as well as to identify regions climatically suitable to a potential invasion.306,307 Such studies will continue to be important for identifying potential suitable areas as well as potential invasion risks from bioenergy crops. In particular, species with a broad range of climatic tolerance (a large climate niche) often are considered among the best candidates for bioenergy feedstocks, a factor that also enhances their invasion risk. However, while such studies typically look at historical/current climatic conditions to determine suitability, they also must include projected changes in climatic variables due to climate change. It is no longer enough to say that because climatic conditions outside of areas being considered for bioenergy crop cultivation are unfavorable for the species, the risk of escape and invasion is necessarily low. Giant reed (Arundo donax), which is currently being cultivated for bioenergy in some states, has been ranked as a likely invasive species on at least 3 published weed risk assessments. Credit: James H. Miller, USDA Forest Service, Bugwood.org.

33 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 6

Conclusions & Recommendations

iven the enormous problems we face from our continued reliance on fossil fuels to meet G our energy needs, finding meaningful alternative energy sources is an important national priority. Energy from biomass resources is likely to be a significant part of America’s energy portfolio in the decades to come. As this report shows, however, the use of non-native and genetically modified native species as bioenergy feedstocks can pose significant risks to native ecosystems. The six case studies highlighted in this report demonstrate that, despite the known invasiveness and harm of many non-native feedstock plants for bioenergy, these plants are nonetheless actively being promoted and used for bioenergy production. If we continue to implement bioenergy feedstock programs without sufficient consideration of the potential ecological and long-term economic costs, it will be only a matter of time until great damage occurs, either ecologically, economically, or both.

Other than some recent initiatives to improve coordination, such as the establishment of the Miscanthus growing in the shadow of the Washington Monument. National Invasive Species Council (NISC),308 the federal Credit: Marilyn Jordan, TNC. government’s regulation of invasive plant species has been reactive, incremental, piecemeal, and focused primarily on protecting agricultural productivity. Its If we continue to implement bioenergy ineffectiveness is apparent with the numerous invasive species, including kudzu, common reed, and purple feedstock programs without sufficient loosestrife that are causing widespread environmental and economic harm across the United States. Current consideration of the potential ecological laws and regulations are entirely insufficient to adequately and long-term economic costs, it will prevent the establishment of new invasives, and to control those already causing problems. Exacerbating be only a matter of time until great the inadequacy of existing programs to prevent invasive species, federal agencies such as USDA face damage occurs, either ecologically, a conflict of interest when they not only promote and economically, or both. support agricultural commodity production, including for bioenergy, but also have the responsibility for enforcement of noxious and invasive species statutes. These challenges are great, but they do not mean that Similarly, the International Union for Conservation of bioenergy development should not go forward; rather, Nature (IUCN) has developed a set of recommendations we must ensure that appropriate precautions are taken on reducing the risk of invasion from bioenergy to develop and use safe bioenergy feedstocks that can feedstocks from an international perspective (See help maintain and restore, rather than threaten, native Box 5).310 habitats. Efforts are underway to identify some key actions that our nation can take to address the bioenergy Building on these recommendations from ISAC and challenge without exacerbating the invasive species IUCN, we emphasize several key actions that we believe problem. The federal Invasive Species Advisory Council must be taken in order to avoid the risk that continued (ISAC) has recommended nine priority actions to the bioenergy development in the United States will also fuel NISC that would help ensure that the United States is a growing invasive species catastrophe. Because the able to meet its commitments to expand bioenergy while ecological and economic costs of invasions are so high, at the same time ensure that our important efforts to fight we believe that a precautionary approach is warranted. invasive species are upheld (See Box 4).309 1. Future bioenergy development should encourage ecological restoration and improve wildlife habitat through the use of ecologically beneficial biomass feedstocks such as waste materials and sustainably collected native Box 4. The Invasive Species Advisory plants and forest residues. Council Recommends the Following Actions to Address the Invasive The use of native grasses and other plants for bioenergy production offers a promising opportunity to support our Potential of Biofuels growing energy needs while at the same time providing important habitat for a range of fish and wildlife species. To maximize benefits to wildlife, research and development 1. Review/Strengthen Existing Authorities. of feedstocks from native grasses should emphasize 2. Reduce Escape Risks. mixtures of grass species interspersed with forbs and 3. Determine Most Appropriate Areas for Cultivation. shrubs. Once established, mixtures of native prairie grasses and forbs can enhance overall biomass yields, 4. Identify Plant Traits that Contribute to or Avoid particularly on areas with degraded soils. Specifically, Invasiveness. research has shown that high diversity plots were found to 5. Prevent Dispersal. be up to 238 percent more productive than monoculture 6. Establish Eradication Protocols for Rotational plots, including plots of monoculture switchgrass that Systems or Abandoned Populations. had significantly reduced yields on degraded soils.311 7. Develop and Implement Early Detection and Moreover, while the establishment of mixed prairie is more complex than establishing a monoculture crop, the Rapid Response. benefits of establishing mixed native plantings may go 8. Minimize Harvest Disturbance. well beyond high yield. Together, these plant communities 9. Engage Stakeholders. can obviate the need for chemical inputs, support numerous species of wildlife, and offer benefits for water management, carbon sequestration, and other important ecosystem services. For example, research shows that biofuels derived from these low-input high diversity mixtures of native grassland perennials can offer a carbon

negative option, as net ecosystem CO2 sequestration

is greater than the fossil CO2 released during the biofuel production process.312

35 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Box 5: IUCN’s Key Recommendations on Biofuels and Invasive Species

1. Follow a precautionary approach when choosing feedstocks. Species should be chosen that minimize the risks to ecosystems and livelihoods from invasion, either by the feedstock species, or associated pests and diseases. Developers should also account for the possible costs of an invasion when choosing species.

2. Work with stakeholders to build capacity. Existing regulations are often robust enough in theory to reduce and contain risks of invasions. The main barrier to their effective enforcement and success comes from lack of capacity and understanding for the need to follow best practices.

3. Comply with local, national, and regional regulations. Regulations add an administrative and financial burden to developers, but they exist to safeguard the environment, the livelihoods of local communities, and the long-term financial sustainability of projects.

4. Develop and follow Environmental Management Plans. Develop appropriate Environmental Management Plans (EMPs) that account for the full range of risks and specify actions to manage the site of production in such a way as to minimize the risk of escape and invasion of surrounding areas, and deal effectively with any potential or actual resulting invasion.

5. Extend planning, monitoring, and assessments beyond the field. Consider developments within the wider context of the landscapes and ecosystems in which they are situated. Risks may extend beyond the site of production especially where adjacent areas may be more susceptible to invasion and the dispersal mechanism enables species to spread beyond the immediate site of a project. Thus, adopting an ecosystem approach when planning developments is preferable to only considering the risks posed by individual species.

Mixed prairie. Credit: Lynn Betts

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 36 Processing potentially invasive bioenergy feedstocks into pellets may reduce the risk of escape during transport. Credit: Anthony DiChello/Bigstock.com.

Considerable attention has already been paid to of renewable energy production systems. Residual switchgrass, which is native to the central and eastern wood products from commercial forestry operations United States. Within its native range, switchgrass are also being used for energy production, increasingly requires minimal management and can be harvested using newer, cleaner combustion technologies. for up to 10 years before replanting. Other grasses Additionally, crop residues can offer another potentially under consideration include broomsedge bluestem sustainable source of biomass production, provided (Andropogon virginicus), little broomstem (Schizachyrium they are removed at sustainable rates that adequately scoparium), big bluestem , and indiangrass.313 It should protect soil. In fact, the USDA and DOE estimate that be noted that concerns have been raised over whether with 25 percent increases in yield, annual supplies of native grasses, such as switchgrass, that have been crop residues could provide 244 million metric tons of selectively bred to be high-yielding sources of biomass, biomass – nearly enough to fulfill the amount necessary may pose a potential invasive risk to native prairie to meet the requirements under the current Renewable stands. Research is currently underway in Minnesota Fuel Standard.316 to better assess the invasive risk as well as the benefits of selectively breeding switchgrass for bioenergy In addition, some scientists have suggested that residual production.314 To reduce the risk of invasion, efforts wood from management of forests affected by major should be made to avoid planting such species near bark beetle infestations, wildfires, hurricanes, and other areas where virgin native grasslands still exist. Similarly, natural disasters could be used as bioenergy resource. as noted previously, there may be the potential for For example, it is estimated that a one-time harvest species native in some areas to become invasive of dead trees associated with mountain pine beetle outside of their endemic ranges - an important outbreaks in areas of the Rocky Mountains in the United consideration in determining where certain feedstocks States and Canada could supply fuel for biomass power may or may not be appropriate. plants or other energy uses for 25 years, while at the same time help reduce the associated risks of major Waste materials from various sources can also serve as wildfires.317 It is important to consider that downed sustainable bioenergy feedstocks. These may include trees and other forest debris left after disturbances wood and food wastes, such as wood from cleanly as well as many logging operations play an important separated municipal solid waste or construction and ecological role by protecting forest soils and providing demolition debris, forest industry residues, food product habitat for wildlife, benefits that would be reduced wastes, sewage, and animal manures.315 In some by their removal.318 As with using control efforts for communities, for example, urban wood and yard wastes currently-problematic invasive species (e.g., kudzu and are now being systematically collected for a wide variety Chinese tallow) as a source of biomass energy, efforts

37 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks to capitalize on harvest of dead trees are necessarily feedstocks are safe by fully identifying and characterizing opportunistic and not necessarily sustainable over the the invasion risk for each feedstock prior to their use long term. Efforts to promote the use of currently-invasive through an environmental assessment process, which species and waste from disasters must first and foremost includes a rigorous WRA. It is critical that each individual be focused on ecosystem restoration. cultivar, not just each species, is fully assessed for its invasion potential. For those species with even a 2. Federal and state governments should moderate risk of invasiveness, we must require carefully- controlled field trials, and establish mandatory mitigation conduct coordinated efforts to prohibit or plans to reduce their risk of escape and invasion prior to restrict the use of known invasive species federal support of those species. as dedicated bioenergy feedstocks through rigorous Weed Risk Assessment (WRA) screening protocols. A first step towards prohibiting

To embrace precaution, we must first and foremost the use of known invasive species take meaningful steps to ensure that species that are as dedicated bioenergy feedstocks already highly invasive or likely to become invasive (as is to ensure that federal and identified by a WRA) are prohibited for use in bioenergy production. The potential ecological and economic risks state mandates and incentives for of a worsening invasive species problem are far too high bioenergy include consistent and for us to ignore our past mistakes – especially where we have an opportunity to be proactive. Indeed, prevention well-coordinated prohibitions of invasive species introduction is the cheapest and most on the use of invasive or cost effective means of reducing the risks to both human and natural communities.319 However, relatively few potentially invasive species. resources are dedicated to preventing the introduction of invasive species compared to expenditures for management and eradication efforts after invasive Another way to prevent the use of risky bioenergy species have gained a foothold, at which point the feedstocks is by instituting federal and state permitting problem is far more expensive and difficult to address.320 requirements for the commercial use of non-native or modified bioenergy species. Florida currently has a A first step towards prohibiting the use of known permitting requirement for cultivation of non-native plants 322 invasive species as dedicated bioenergy feedstocks is to (including GM plants) intended for biofuel production. ensure that federal and state mandates and incentives According to their requirement, non-native biomass for bioenergy include consistent and well-coordinated plantings spanning more than two acres require a prohibitions on the use of invasive or potentially invasive permit from the Florida Department of Agriculture species. Through mandates, incentives, and agency and Consumer Services. While the permit process purchases, the federal government is currently putting disincentivizes the use of invasive species, it does not large amounts of money into bioenergy development. necessarily restrict the cultivation of potentially invasive The Department of Defense, for instance, recently species such as giant reed and napiergrass that not are signed a contract to buy almost half of a million gallons listed on Florida’s official noxious weed list. Permitting of biofuels for the U.S. Navy.321 With limited funds being programs can be tied to a WRA to evaluate potential spent to promote second and third generation bioenergy bioenergy feedstocks and restrict or regulate use of any production, native and non-invasive species should be species with high probability of becoming invasive. As prioritized. At the very least, federal funds should not a basic starting point, comprehensive WRAs should be be used to promote or purchase bioenergy feedstocks, required for all varieties of potential bioenergy feedstocks including through funding research projects, until the prior to their use to help identify the specific sources of 323 federal government has first demonstrated that the and reasons for potential risk of invasiveness. Species

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 38 with low risk of invasion could be permitted, and those However, the burden of developing such actions should with even a moderate risk of invasion would have to meet not fall exclusively on the government and taxpayers. certain requirements, such as having monitoring and Companies who grow potentially invasive bioenergy eradication protocols, in place (See Recommendation #4). feedstocks should be required to pay up-front costs for control of the specific species they are growing The USDA recently released an updated weed screening into a state account. These funds should be sufficient tool to identify invasive potential.324 While WRAs alone to cover costs associated with containment, control, may not be enough to fully and accurately assess management, and subsequent restoration efforts. risk, and the screening tools must be continuously Those growing varieties that have higher risk according be improved upon as our understanding of invasive to a WRA would pay higher fees than those scoring risks deepens, the WRA offers a good place for lower risk. The state of Florida currently has such a agencies to start. bonding program for bioenergy feedstocks that is tied to its permitting program. The proceeds of the 3. State and federal governments should bonding program go to fund eradication efforts of invasive bioenergy crops. Bonding requirements can be implement rigorous monitoring, early set up to include rigorous monitoring, detection, and detection, and rapid response protocols, eradication protocols. Bonding requirements are currently paid for through insurance bonding or other used in a variety of commercial operations including financial mechanisms. hazardous waste treatment facilities, mining, and oil- carrying vessels.327 All too often, the cost of controlling an invasion by a non-native species is borne by state and federal 4. Feedstock producers should adopt best governments. In California, for instance, more than management plans for monitoring and $70 million dollars have been spent over the past 15 years to control giant reed; invasion by the plant mitigation to reduce the risk of invasion. has caused extensive damage to ecosystems and Because the full risk of invasion from biomass human infrastructure in many of the state’s coastal feedstocks is often unknown, having a clear plan for watersheds.325 Putting resources up front into monitoring and remediation is critical, even for projects monitoring, early detection, and rapid response can save using species with a low risk of invasion. Before any money in the long-term. Both state and federal agencies feedstock becomes commercialized, companies that have established so-called Early Detection-Rapid grow potentially invasive bioenergy feedstocks should Response (EDRR) programs to provide an important be required to establish management plans that early line of defense against invasive species, before they embrace best practices for establishing, harvesting, cause potentially irreparable harm to natural systems.326 transporting, and storing feedstocks to reduce the risks of invasion.328 Best management practices may include timing harvests to minimize spread of seeds, maintaining clean equipment, using closed transportation systems to transfer feedstocks to production facilities, and putting an eradication plan into place before production.329 For example, studies suggest that, with advances in processing equipment, potentially invasive plant feedstocks can be processed into useable forms such as pellets where they are harvested, before they are transported to the energy production facilities.330 Such plans should also include avoidance and monitoring for pests and pathogens that might spread from cultivation sites and production facilities, both to protect Volunteers cleaning up invasive seaweed in Hawaii. the bioenergy crop and other species that might be Credit: NOAA.

39 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks impacted. Frequent monitoring of nearby fields and help to clarify where responsibility lies for covering any roadways during the duration of the project and beyond costs related to an invasion and encourage the adoption also should be a key component of any management of best practices to protect economic investments in plan. In addition, bioenergy developers should be biofuels in the region.”335 required to regularly monitor their processes, from cultivation and harvest to delivery and production, and 6. Governments and businesses should they must develop comprehensive contingency plans better account for the economic risks that establish specific actions in the event of escape.331 associated with invasiveness of feedstocks Additionally, there are a number of voluntary certification programs for sustainable biomass feedstocks that when assessing relevant costs and benefits currently exist or are being established, including the of potential bioenergy projects. Roundtable on Sustainable Biofuels,332 the Council for Sustainable Biomass Production,333 and the Forest In decisions concerning the cultivation of non-native Stewardship Council.334 Many of these certification species, the benefits of the species’ use must be processes include carefully considered guidelines that weighed against the potential ecological and economic can help companies in feedstock selection, mitigation risks that may arise should the species become invasive. and monitoring of potentially invasive biomass species. In fact, while the 1999 Executive Order 13112 was established to help protect the nation against actions that 5. The federal government should assign cause or contribute to the introduction of harmful invasive species, exceptions are granted provided that “the liability to feedstock producers for damages benefits of such actions clearly outweigh the potential from and remediation of invasions by harm.”336 In addition to identifying the ecological risks of feedstock varieties that they develop. alternative bioenergy feedstocks, there is a critical need to improve our understanding and consideration of the As mentioned above, once an invasive species spreads potential economic risks associated with species that into native ecosystems, the costs for eradication, have or may become invasive. The particular challenge monitoring, and ecosystem restoration are often borne here is that, while identifying the economic benefits of by the state or federal government. There is currently bioenergy is relatively straightforward, it is much more minimal incentive for individual landowners to control difficult to compute the economic costs associated with the spread of weeds from an intentional planting or the ecological impacts of invasive species, especially introduction onto an adjacent landowner’s property, with since many of the costs will be realized over the long- civil liability for the spread of weeds onto an adjacent term.337,338 Without truly acknowledging the full potential landowner’s property varying widely across states. costs of invasions, decisions will likely more often than Accordingly, there is minimal incentive for bioenergy not skew in favor of the economic gains from bioenergy. producers to prevent the spread of invasive species. As the pace of research and experimentation with non- Certainly the economic, social, and ecological costs native and GM crops grown for bioenergy continues associated with climate change, global security, and to accelerate, it is critical that companies be held other major problems associated with fossil fuels that are accountable for the unintended consequences should the impetus for bioenergy development are by no means the feedstocks become invasive and spread. Assigning inconsequential. However, as Low, Booth, and Sheppard liability for damages and remediation will incentivize (2011) argue, the “[p]romotion of biofuels as solution those companies to take precautionary measures to to urgent global problems encourages trivialization of reduce the risk of invasion – those producers who have weed problems.” What we need are meaningful policies in good faith implemented best management practices and programs that help promote a healthy, sustainable (see recommendation #4), including choosing low-risk bioenergy economy, while ensuring that our important feedstocks, would not then be held liable. This idea of ecological values – which are often undervalued in the a “polluter pays” principle for bioenergy feedstocks has marketplace – are protected.339 been recommended by IUCN, who states that “This will

Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 40 Concluding Thoughts

As this report has shown, the rapid expansion of bioenergy production in the United States has generated considerable interest in the use of non-native and genetically modified biomass feedstocks that have the potential to become ecologically-damaging invasives. Should these species escape and become established in nearby natural areas, the results could be costly and devastating for native ecosystems. Despite this, few safeguards exist in law to prevent the spread of invasive species through bioenergy cultivation, and current risk assessment methodologies alone may not be sufficient. Policy makers, federal and state agencies, landowners, feedstock producers, and the public all need to become more aware of the potential for bioenergy feedstocks to become invasive. As we move towards a clean energy future, we must do so cautiously and responsibly. Invasive species can wreak havoc on ecosystems and economies; as we try to address the problem of global climate change, we must avoid worsening the invasive species problem. With foresight and careful screening, we have important opportunities to minimize and, where possible, prevent negative impacts of biomass feedstocks on functioning ecosystems. By implementing common-sense policies based first and foremost on precaution, we can significantly Native grasses not only reduce the risk of invasion, but they also reduce the risk of invasion and help ensure a truly provide habitat for species such as this wild turkey. Credit: NRCS. sustainable bioenergy industry.

As we move towards a clean energy future, we must do so cautiously and responsibly. Invasive species can wreak havoc on ecosystems and economies; as we try to address the problem of global climate change, we must avoid worsening the invasive species problem. With foresight and careful screening, we have important opportunities to minimize and, where possible, prevent negative impacts of biomass feedstocks on functioning ecosystems.

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Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 46 166 USDA APHIS, 2010a. 181 Boyd, David. 1997. Eucalyptus Removal on Angel Island. In California 167 Hinchee, M., W. Rottman, L. Mullinax, C. Zhang, S. Chang, M. Exotic Pest Plant Council, 1997 Symposium Proceedings, 25-33. Cunningham, L. Pearson, and N. Nehra. 2009. Short-rotation woody California Invasive Plant Council, Sacramento, CA. crops for bioenergy and biofuels applications.” In Vitro Cellular and 182 Stannard, M. and W. Crowder. 2011. Reed Canarygrass. USDA Developmental Biology.—Plant. 45: 619-629. NRCS Plant Guide. USDA Pullman Plant Material Center, Pullman, WA. 168 Voosen, Paul. “USDA Weighs Plan to Bring GM Eucalyptus to 183 Merigliano, MF and P Lesica. 1998. The native status of reed Southeast Pinelands.” The New York Times. 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University of Florida IFAS Extension, Publication #SS- Modification of Algae: Impacts on Biomass Energy, Environment, Public AGR-242. . Health & Food Safety.” Congressional Briefing, U.S. Capitol Visitor 232 The U.S. Bureau of Reclamation, H.T. Cory, and F.W. Hanna. 1919. Center, October 1, 2010. Development of Unused Lands: Letter from the Secretary of the Interior 217 Lardizabal, S. “Beyond the Refugium: A Macroalgae Primer.” Transmitting Report on the Development of the Unused Lands of the Reefkeeping. http://reefkeeping.com/issues/2007-01/sl/index.php Country. Washington Government Printing Office, Washington, D.C. (accessed March 8, 2012). 233 Woodard, K.R. and L.E. Sollenberger. 2009. Production of biofuel 218 Maron, 2010. crops in Florida: Elephantgrass. University of Florida IFAS Extension, 219 Hong, Y., A. Steinman, B. Biddanda, R. Rediske, and G. Publication #SS-AGR-297. Fahnenstiel. 2006. Occurrence of the toxin-producing cyanobacterium 234 USDA Research, Education & Economics Information System Cylindrospermopsis raciborskii in Mona and Muskegon Lakes, Michigan. (REEIS). “Developing non-invasive, genetically improved genotypes of the Journal of Great Lakes Research 32: 645-652. biofuel and forage crop napiergrass.” http://www.reeis.usda.gov/web/ 220 Schaffelke, B and CL Hewitt. 2007. Impacts of introduced crisprojectpages/222322.html. (accessed March 8, 2012). seaweeds. Botanic Marina 50: 397-417. 235 Odero and Rainbolt, 2009.

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49 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 271 Raghu et al., 2006. 290 ArborGen, LLC. 2012. Availability of an Environmental Assessment 272 Section 9001 of the 2008 Farm Bill, Public Law 110-246. for Controlled Release of a Genetically Engineered Eucalyptus Hybrid. 77 273 Endres, J. M.. 2011. No Free Pass: Putting the “Bio” in Biomass, Federal Register 7123. Natural Resources & Environment 26,,:33. 291 Standards Australia, Standards New Zealand and CRC Australian 274 75 Federal Register 66202, 66208 (Oct. 27, 2010). Weed Management. 2006. HB 294-2006 National Post-border Weed 275 75 Federal Register 66202, 66210 (Oct. 27, 2010). Risk Management Protocol. Standards Australia International Ltd., 276 Environmental Law Institute. 2010. Status and Trends in State Sydney and Standards New Zealand, Aukland. Invasive Species Policy: 2002-2009. Washington, D.C. 292 Davis, et al., 2010. 277 Burgiel, S., G. Foote, M. Orellana, and A. Perrault. 2006. 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Maxwell. 2011. 285 21 U.S.C. § 301 et seq. Refinement of weed risk assessments for biofuels using Camelina sativa 286 7 C.F.R. § 340. In January, 2004, USDA proposed to regulate as a model species. Journal of Applied Ecology 48: 989-997. genetically engineered plants under its noxious weed authority, in addition 302 DiTomaso et al., 2010. to the established plant pest authority. 69 Federal Register 3271 (Jan. 303 Cousens, R. 2008. Risk assessment of potential biofuel species: 23, 2004). Although the USDA has not yet finalized this proposed rule, An application for trait-based models for predicting weediness. Weed the agency’s recent review of genetically engineered Kentucky Bluegrass Science 56: 873-882. under the noxious weed provisions of the Plant Protection Act provides 304 DiTomaso, Barney, and Fox, 2007. a secondary regulatory route for genetically engineered plants. See 305 Low, Booth, and Shephard, 2011. 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Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 50 314 Eckberg, J. 2011. Evaluation of switchgrass as a biofuels crop. 327 Boyd, James. Financial Responsibility for Environmental Obligations: Minnesota Environment and Natural Resources Trust Fund M.L. 2011 Are Bonding and Assurance Rules Fulfilling Their Promise? Washington, Work Plan. http://www.lccmr.leg.mn/all_projects/2011_projects/ DC: Resources for the Future, 2001. http://www.rff.org/documents/ workplans_may/_06c_workplan.pdf RFF-DP-01-42.pdf (accessed March 13, 2012). 315 Kemp and Sibbing 2010. 328 Barney and DiTomaso, 2008. 316 Fargione et al. 2009. 329 Barney and DiTomaso, 2011. 317 Ibid. 330 Young, S.L., G. Gopalakrishnan, and D.R. Keshwani. 2011. Invasive 318 Pedlar, J.H., J.L. Pearce, L.A. Venier, and D.W. McKenney. 2002. plant species as potential bioenergy producers and carbon contributors. Coarse woody debris in relation to disturbance and forest type in boreal Journal of Soil and Water Conservation 66: 45A-50A. Canada. Forest Ecology and Management 158: 189-194. 331 Barney and DiTomaso, 2008. 319 Emerton, L. and G. Howard. 2008. A Toolkit for the Economic 332 Ecole Polytechnique Federale de Lausanne (EPFL). “Roundtable on Analysis of Invasive Species. The Global Invasive Species Programme, Sustainable Biofuels RSB.” http://rsb.epfl.ch/ (accessed March 9, 2012) Nairobi, Kenya. 333 Council on Sustainable Biomass Production. “CSBP Provisional 320 Davies and Johnson, 2009. Standard for Sustainable Production of Agricultural Biomass now 321 Medici, Andy. “DoD Makes Record Biofuel Purchase for U.S. Navy.” available.” http://www.csbp.org/ (accessed March 9, 2012) DefenseNews. December 6, 2011. 334 Forest Stewardship Council. http://www.fsc.org/ (accessed March http://www.defensenews.com/article/20111206/ 9, 2012) DEFSECT03/112060305/DoD-Makes-Record-Biofuel-Purchase-U- 335 IUCN. 2009. Guidelines on Biofuels and Invasive Species. Gland, S-Navy Switzerland: IUCN. 20pp. 322 Biomass Plantings, Florida Administrative Code § 5B-57.011. 336 64 Federal Register 6183, 6186. (Feb. 8, 1999). 323 DiTomaso et al., 2010. 337 Davis, et al., 2010. 324 Koop, AL, L Fowler, LP Newton, and BP Caton. 2011. Development 338 Simberloff, D. 2005. The politics of assessing risk for biological and validation of a weed screening tool for the United States. Biol. invasions: The USA as a case study. Trends in Ecology and Evolution 12: Invasions 14: 273-294. 216-222. 325 Giessow et al., 2011. 339 Low, T., C. Booth, and A. Sheppard. 2011. Weedy biofuels: What can 326 Westbrooks, R.G. 2011. New approaches for early detection and be done? Current Opinion in Environmental Sustainability 3: 55-59. rapid response to invasive plants in the United States. Weed Technology 18: ]1468-1471.

51 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks A mixture of native grasses and forbs, which can support bioenergy production as well as provide important habitat for a range of fish and wildlife species. Credit: Lynn Betts, NRCS.

e now have an opportunity to prevent irreparable harm by heeding W sensible precautions in order to avoid the risk that continued bioenergy development in the United States will fuel a growing invasive species catastrophe. With foresight and careful screening, we can minimize and, where possible, prevent negative impacts of biomass feedstocks on functioning ecosystems. Bioenergy can be an important part of a sustainable energy future, but only if it is produced in a way that safeguards native habitats and minimizes the risk of invasion. National Wildlife Federation National Advocacy Center 901 E St. NW, Suite 400 Washington, DC 20004 www.nwf.org